Ian Ryan

Ian Ryan

Partner - Business Crime and Regulatory

A close look at the Annual Suspicious Activity Report (SAR) for 2013/2014 reveals some interesting statistics. Of the 354,186 SARs submitted 82.18% were from the banking sector, 19.67% were from the legal sector and 4.36% from estate agents (before the recent documentary “From Russia with cash” obviously).

Of these 4,155 (or 14.1%) were for consent and 11.5% (477 by my maths) of those consents were refused. And 35 people were arrested as a result.

Obviously the NCA trumpets this as a great triumph, but it does make you wonder what happens to the great majority of SARs and consent applications and whether needless inconvenience is being caused to many for no particularly good reason, by banks who are hopelessly risk adverse and cannot be held to account as long as they have a “suspicion”.

The lack of legal SARs is taken by some (the police) to indicate that solicitors are complicit with criminals, whilst others (me) think they are beginning to understand the reporting requirements better. The Solicitors Regulation Authority (SRA) of course spinelessly swallowed the National Crime Agency (NCA) line and announced a thematic Anti Money Laundering (AML) review which apparently created a pipeline of cases. We shall see.

It will also be interesting to see how many professional enablers the new offences catch, as opposed to those that escaped justice before with the inadequate laws we apparently had (which seemed to work ok in the Ibori case).

And estate agents look as if they will have to up their game, particularly with the Royal Institution of Chartered Surveyors (RICS) putting its supervisory body under the Money Laundering Regs, while amusingly also carrying out an investigation into Channel 4’s From Russia With Cash.

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