Complete the external Suspicious Activity Report (SAR) with How to manage communications with law enforcement after an SAR has sufficient information and submit this to the law enforcement been submitted agency within agreed timescales Constructive trusteeship and how to recognise and manage the risk of it Report the reasons for your suspicions clearly and accurately Enforcement and discovery orders in civil cases and the response and determine any additional information which may be required to required contribute to or contextualise the reasons for the suspicion How to proceed with client relationships and transactions once an SAR Seek consent from law enforcement agencies, where required has been made to law enforcement under applicable legislation, to proceed with a suspected transaction or activity What to do when consent to proceed with client relationships and transactions is withheld by law enforcement Analyse the consent of law enforcement to ascertain exactly what has been consented to and your organisation’s ongoing Production orders, restraint orders and confiscation orders and the obligations to law enforcement response required by them Respond within the specified timescale to appropriate orders The importance and value of client review techniques in the light of issued by a with all pertinent information that falls within the experience of SARs scope of the order The records that need to be securely retained, and for how long Your organisation’s requirements relating to the application of codes, Conduct client reviews which take into account features common laws regulatory requirements and guidance, including data protection and in suspect client relationships health and safety, as they impact on your activities Keep accurate and complete records of external SARs, storing them securely and ensuring that they are only available to authorised persons
Complete the external Suspicious Activity Report (SAR) with sufficient information and submit this to the law enforcement agency within agreed timescales Report the reasons for your suspicions clearly and accurately and determine any additional information which may be required to contribute to or contextualise the reasons for the suspicion Seek consent from law enforcement agencies, where required under applicable legislation, to proceed with a suspected transaction or activity Analyse the consent of law enforcement to ascertain exactly what has been consented to and your organisation’s ongoing obligations to law enforcement Respond within the specified timescale to appropriate orders issued by a with all pertinent information that falls within the scope of the order Conduct client reviews which take into account features common in suspect client relationships Keep accurate and complete records of external SARs, storing them securely and ensuring that they are only available to authorised persons How to manage communications with law enforcement after an SAR has been submitted Constructive trusteeship and how to recognise and manage the risk of it Enforcement and discovery orders in civil cases and the response required How to proceed with client relationships and transactions once an SAR has been made to law enforcement What to do when consent to proceed with client relationships and transactions is withheld by law enforcement Production orders, restraint orders and confiscation orders and the response required by them The importance and value of client review techniques in the light of experience of SARs The records that need to be securely retained, and for how long Your organisation’s requirements relating to the application of codes, laws regulatory requirements and guidance, including data protection and health and safety, as they impact on your activities
nos-aml-april-12.docx