Recent statistics from the Department of Internal Affairs' (DIA) ‘AML/CFT Suspicious Activity Reports – Thematic Review’ have shed light on the significance of vigilance within the financial sector. The numbers offer insights into the extent of suspicious activities identified and reported as well as key findings that all REs should pay attention to.

So, what do these stats tell us?

The review encompassed 56 reporting entities, with DIA regulators evaluating their compliance with the AML/CFT Act 2009. The entities were required to submit their Suspicious Activity Reporting (SAR) policies, procedures, and controls, confirm their registration with GoAML, and provide SAR submission data for the period between November 1, 2021, and October 30, 2022.

Among the 56 entities, the review revealed that 21 were fully compliant, 30 were partially compliant, and 5 were non-compliant regarding their policies, procedures, and controls. Out of these entities, 55 were registered with GoAML, and only 11 had filed SARs between 1 November 2021, and 30 October 2022.

Despite overall compliance, the review's key findings highlighted several areas for improvement:

• There was a recurring misunderstanding regarding the requirement to undertake enhanced Customer Due Diligence on customers connected to a filed SAR.
• The review emphasized the need to enhance controls for internal reporting, escalation, and meeting the three-working-day reporting requirement.
• Caution was advised when using templates for SAR policies, procedures, and controls, as customisation to unique business needs is essential to ensure compliance with the Act.

Overall the review paints a picture of progress in the ongoing fight against financial crimes, and serves as an important reminder to REs of the indispensable role they play  in maintaining a safe and secure financial ecosystem. As we move forward, it is crucial to remember that vigilance remains the cornerstone of effective AML/CFT efforts, and reporting suspicious activities is a responsibility that cannot be taken lightly.

For more information about when and how to submit a SAR, feel free to contact our team directly.