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Article
Publication date: 29 November 2023

Hussain Syed Gowhor

This study aims to evaluate the suspicious transaction reporting (STR) as a financial intelligence tool to identify the potential strengths and limitations of STR and to come up…

Abstract

Purpose

This study aims to evaluate the suspicious transaction reporting (STR) as a financial intelligence tool to identify the potential strengths and limitations of STR and to come up with the criteria, which will make this tool an effective one in early detection of terrorist financing activities.

Design/methodology/approach

Considering the research aim, this research uses the funnelling method for identifying effectiveness criteria. Funnelling is a method of literature review that helps find pertinent literature by refining the search through filtering the available research (Ridley, 2008). Using this method, the researcher first applied the criteria of actionable intelligence to filter the financial intelligence tools to select the most promising and important tool (suspicious transaction reporting) for early detection of terrorist financing activities. The funnelling method was also applied to derive the effectiveness criteria from the operational features, and corresponding limitations, of the suspicious transaction reporting system. The funnelling method was also used to identify those operational features and limitations of suspicious transaction reporting that have the most direct relevance to the early detection problem of suspicious transaction reporting.

Findings

There are some operational features of STR that give rise to certain limitations that undermine its effectiveness in terms of early detection of terrorist financing activities. The limitations of STR necessitate a search for criteria that will make STR effective in early detection of terrorist financing activities. Based on the operational features and their corresponding limitations, effectiveness criteria for STR have been derived in this study. It is shown how these effectiveness criteria can remove the limitations of STR.

Research limitations/implications

The list of operational features and the corresponding limitations based on which the effectiveness criteria have been derived may not be exhaustive. There may have other operational features, and corresponding limitations that also make STR largely ineffective in the early detection of terrorist financing activities, and for which more effectiveness criteria should also be derived.

Practical implications

The limitations and the effectiveness criteria will pave the way for redesigning STR in such a way that will make it highly useful for detecting financing activities relating to imminent terrorist attacks.

Social implications

The society will experience fewer terrorist attacks that will make the society peaceful, happy and vibrant.

Originality/value

In this study, the effectiveness criteria of STR for early detection of terrorist financing activities have been derived in an innovative way by deducing them from the operational features of STR and the corresponding limitations.

Details

Journal of Financial Crime, vol. ahead-of-print no. ahead-of-print
Type: Research Article
ISSN: 1359-0790

Keywords

Article
Publication date: 3 July 2017

Robert Michael Axelrod

This paper aims to suggest alternative suspicious activity analyses to improve the focus of financial institution reporting to law enforcement and to identify some limitations in…

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Abstract

Purpose

This paper aims to suggest alternative suspicious activity analyses to improve the focus of financial institution reporting to law enforcement and to identify some limitations in the current practice.

Design/methodology/approach

This paper employs the consideration of US and Financial Action Task Force policies and text sources of suspicious activity reporting in the anti-money laundering context in light of how the reports are used. Furthermore, there is consideration of confidentiality and privacy constraints on public and private sector in assessing strategies to make the reporting process more effective and aiding the discovery and investigation of crime.

Findings

The current suspicious activity reporting process takes advantage of the business acumen of financial institutions to identify unusual or unexplained behavior that may assist law enforcement in criminal investigations and prosecutions. It is successful in that regard. However, the process has not been tuned to identifying criminal behavior through systematic feedback. As an alternative to feedback, analysis of criminal organizations vis-à-vis the transactions that flow through a reporting institution is suggested as a means to creating better tuning. The analysis could be accomplished either by law enforcement or by select institutions; but in either case, hurdles of confidentiality and/or privacy would have to be overcome.

Originality/value

Creating a process for law enforcement and/or reporting institutions to map known criminal activity on a transaction set would allow a new assessment of the role of financial institutions in this regard, and may allow policymakers to reassess whether the financial institutions’ efforts currently required would be more productive if redirected to focus more on criminal as opposed to merely suspicious activity.

Details

Journal of Financial Crime, vol. 24 no. 3
Type: Research Article
ISSN: 1359-0790

Keywords

Article
Publication date: 23 June 2023

Mario Menz

This paper aims to show how financial services firms determine whether customer transactions or behaviours meet the threshold for suspicious activity reporting mandated by the…

Abstract

Purpose

This paper aims to show how financial services firms determine whether customer transactions or behaviours meet the threshold for suspicious activity reporting mandated by the Terrorism Act 2000 and the Proceeds of Crime Act 2002, and how suspicious activity reporting is executed in practice.

Design/methodology/approach

Semi-structured interviews have been carried out among compliance professionals in UK financial services.

Findings

Two issues related to suspicious activity reporting have been identified. Firstly, a widespread misunderstanding about the tipping-off offence under s. 333 Proceeds of Crime Act 2002 has been identified, which appears to be a root cause for poor quality as well as over-reporting of suspicious activity. Secondly, issues related to the notice and moratorium periods used by the UK’s National Crime Agency appear to deter reporting of suspicious activity related to live transactions.

Practical implications

The paper makes suggestions for changes financial services firms and the UK’s National Crime Agency can make to improve the effectiveness of suspicious activity reporting.

Originality/value

The paper provides valuable insights which can be used to limit the flow of criminal funds, improve the quality of suspicious activity reporting and enhance the effectiveness of law enforcement agencies.

Details

Journal of Financial Crime, vol. 31 no. 2
Type: Research Article
ISSN: 1359-0790

Keywords

Article
Publication date: 3 January 2017

Carlos Siu Lam and Malcolm Greenlees

Apart from presenting an overview and background on anti-money laundering (AML) rules and procedures for casinos in both Macao and the USA, this paper aims to examine the…

Abstract

Purpose

Apart from presenting an overview and background on anti-money laundering (AML) rules and procedures for casinos in both Macao and the USA, this paper aims to examine the differences in their regulatory approaches with regard to their existing AML reporting processes and discusses possible weaknesses in their respective regulatory regime.

Design/methodology/approach

Given that the regulations and statistics on the AML issues may not all be publicly available, the authors managed to secure some data from the bureaus concerned through published reports and interviews with government officials. Regarding the AML procedures in casinos, the authors attempted to go over the annual reports published by the casinos for submission to the Hong Kong Stock Exchanges and Clearing Limited because all these casinos are listed companies in Hong Kong.

Findings

This paper analyzes the trends in reporting numbers and the categorization of the types of suspicious activity reports filed both in Macao and the USA. While the US suspicious activity reporting focuses on efforts to avoid currency reporting, Macao emphasizes improper or inadequate documentation and identification.

Originality/value

This paper is one of the few articles comparing the AML rules and procedures between casinos in the USA and Macao. It seeks to highlight the differences in their regulatory approaches and discusses the expected future direction of AML legislation.

Details

Journal of Money Laundering Control, vol. 20 no. 1
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 6 November 2018

Jeff Gruenewald, Brent R. Klein, Grant Drawve, Brent L. Smith and Katie Ratcliff

The purpose of this paper is to provide a metric for validating the Nationwide Suspicious Activity Reporting (SAR) Initiative’s (NSI) sixteen-category instrument, which is…

Abstract

Purpose

The purpose of this paper is to provide a metric for validating the Nationwide Suspicious Activity Reporting (SAR) Initiative’s (NSI) sixteen-category instrument, which is designed to guide law enforcement in the collection and analysis of suspicious behaviors preceding serious crimes, including terrorist attacks.

Design/methodology/approach

Data on suspicious preoperational activities and terrorism incident outcomes in the USA between 1972 and 2013 come from the American Terrorism Study (ATS). Using a mixed-method approach, the authors conduct descriptive and multivariate analyses to examine the frequencies of the least and most prevalent suspicious activities (or SAR indicators) and how they predict the likelihood of terrorism prevention. In addition, the authors contextualize how configurations of SAR indicators are associated with the successful thwarting of terrorism incidents by law enforcement using an analytical method known as conjunctive analysis of case configurations (CACC).

Findings

The study reveals several key findings. First, certain behaviors categorized as suspicious, such as making threats, occur more frequently than others. Second, making threats, conducting surveillance and terrorist recruitment/financing predict law enforcement interdiction in terrorism plots, while misrepresentation (or the manufacturing and use of false documents) is more associated with terrorist success. Third, prevalent SAR indicators operate differently in the context of various combinations of suspicious activities to shape the likelihood for law enforcement interdiction.

Research limitations/implications

The current study’s findings may not be generalizable to other forms of violent extremism and terrorism outside of the USA.

Practical implications

This study illuminates opportunities for the NSI to provide law enforcement with the necessary tools to reduce terrorism risk and prevent future attacks.

Originality/value

To our knowledge, no scholarly work to date has assessed how observable behavioral indicators of suspicious preoperational activities affect the outcomes of terrorist plots.

Details

Policing: An International Journal, vol. 42 no. 1
Type: Research Article
ISSN: 1363-951X

Keywords

Article
Publication date: 1 October 2018

Brett Coombs-Goodfellow and Mark Eshwar Lokanan

This paper aims to examine the influence Jones’ Moral Intensity Model (1991) has on the decision-making process of anti-money laundering (AML) compliance officers charged with…

Abstract

Purpose

This paper aims to examine the influence Jones’ Moral Intensity Model (1991) has on the decision-making process of anti-money laundering (AML) compliance officers charged with reporting suspicious money laundering transactions in Jersey.

Design/methodology/approach

Ten interviews were conducted to elicit participants’ views on the six dimensions of moral intensity and their influence on the compliance officers’ decision to submit a suspicious activity report (SAR) of potential money laundering.

Findings

The findings indicate that the officers’ moral intensity to submit a SAR seems to be heavily influenced by issue-specific contextual factors. Contexts (legal and legislative mandates) seem to have more of an effect on the moral intent and actions of the officers rather than directly affecting the decision to submit a report of a suspicious money laundering transaction.

Research limitations/implications

The paper lays the groundwork for further work in this area and calls on researchers to develop instruments that can enhance the measurements of the dimensions of moral intensity.

Practical implications

The setting (AML in the financial sector) is both timely and extremely interesting to keep studying, particularly in Jersey because of its dubious sensitive particularities.

Originality/value

The study is the first to examine Jersey AML sector through the lens of moral intensity. In this sense, the paper poses interesting questions, namely, to explore the dynamic complexities experienced by compliance officers in Jersey to detect and report suspicious money laundering activities and the decision-making criteria of actually submitting a SAR.

Details

Journal of Money Laundering Control, vol. 21 no. 4
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 6 November 2023

Simon D. Norton

This study aims to evaluate the advantages and disadvantages of auditor mandatory suspicious activity reporting versus the exercise of professional judgement in the anti-money…

Abstract

Purpose

This study aims to evaluate the advantages and disadvantages of auditor mandatory suspicious activity reporting versus the exercise of professional judgement in the anti-money laundering regimes of the UK and the USA.

Design/methodology/approach

The research draws upon the following sources. Firstly, statistics provided by the UK National Crime Agency, 2019 (NCA) regarding suspicious activity report (SAR) filing rates. Secondly, anti-money laundering legislation in the USA and UK. Thirdly, statements made in the political domain in the USA, particularly those which raised constitutional concerns during the progress of the Patriot Act 2001. Finally, statements and recommendations by a UK Parliamentary Commission enquiring into the effectiveness of the suspicious activity reporting regime.

Findings

The UK reporting regime does not accommodate professional judgement, resulting in the filing of SARs with limited intelligence value. This contrasts with discretionary reporting in the USA: voluntary reporting guides and influences auditor behaviour rather than mandating it. Defensive filing by UK auditors (defence to anti-money launderings [DAMLs]) has increased in recent years but the number of SARs filed has declined.

Originality/value

The study evaluates auditor behavioural responses to legislative regimes which mandate or alternatively accommodate discretion in the reporting suspicion of money laundering. Consideration of constitutional and judicial activism in this context is a novel contribution to the literature. For its theoretical framework the study uses Foucault’s concept of discipline of the self to evaluate auditor behaviour under both regimes.

Details

Journal of Money Laundering Control, vol. 27 no. 3
Type: Research Article
ISSN: 1368-5201

Keywords

Article
Publication date: 5 July 2013

Jun Tang and Lishan Ai

This paper proposes to use system integration between customer relationship management (CRM) and anti‐money laundering (AML) suspicious data reporting in commercial banks to…

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Abstract

Purpose

This paper proposes to use system integration between customer relationship management (CRM) and anti‐money laundering (AML) suspicious data reporting in commercial banks to increase the initiative of suspicious transaction identification, reduce the false reporting rates, and improve the intelligence quality.

Design/methodology/approach

This paper introduces the structure of CRM in commercial banks, discusses deficiencies of the current AML data reporting system, and designs the layering of CRM and AML transaction identification module.

Findings

This paper finds that the functions of customer behavior analysis and customer background investigation of CRM system can be redesigned and used for increasing the quality of AML suspicious transaction reporting in commercial banks.

Originality/value

This paper creatively proposes that system integration of CRM and AML suspicious transaction reporting can make a contribution to reducing the AML cost for commercial banks.

Details

Journal of Money Laundering Control, vol. 16 no. 3
Type: Research Article
ISSN: 1368-5201

Keywords

Book part
Publication date: 26 January 2011

Kenneth Farrall

The Nationwide Suspicious Activity Reporting Initiative (NSI) is the focal point of the Information Sharing Environment (ISE), a radical reformulation of policies governing…

Abstract

The Nationwide Suspicious Activity Reporting Initiative (NSI) is the focal point of the Information Sharing Environment (ISE), a radical reformulation of policies governing government intelligence activities within US borders. In the wake of the September 11th attacks, long-standing informational norms for the production, use, and circulation of domestic intelligence records containing personal information are being replaced with far less restrictive norms, altering a status quo that had been in effect since mid-1970s. Although the NSI represents an unprecedented expansion of human resources dedicated to the collection and production of domestic intelligence, it is not well known in privacy advocacy community. This chapter considers these and other terms in the context of relevant US law and policy, including the Privacy Act of 1974, the E-Government Act of 2002, Executive Order 12333, and 28 CFR Part 23. In addition to describing the federal (ISE-SAR) standard, the chapter examines the critical role of guidance in the logic of suspicious activity report (SAR) production, and the problematic role finished ISE-SARs seem to play in the matrix of federal and state-level watch lists. The program, if not properly regulated, could pose a considerable threat to personal privacy and the life chances and self-determination of all US persons. The chapter considers this threat in terms of Nissenbaum's (2010) “contextual integrity,” a theory of context-relative informational norms.

Article
Publication date: 23 August 2021

Hussain Syed Gowhor

This paper aims to inform the readers about the existing financial intelligence tools that are being used by financial intelligence units. It tries to demonstrate, with the help…

Abstract

Purpose

This paper aims to inform the readers about the existing financial intelligence tools that are being used by financial intelligence units. It tries to demonstrate, with the help of a literature review, what the limitations of these tools are and how these limitations hinder the potential of the financial intelligence tools for early detection of terrorist financing activities.

Design/methodology/approach

The literature review method was adopted to discuss the financial intelligence tools, their limitations and the implications of the limitations for early detection of terrorist financing activities.

Findings

It was found that although the financial intelligence tools were introduced with a view to detect terrorist financing activities early, there are some inherent limitations of the tools relating to technical design features and operational procedures that hinder early detection of terrorist financing activities.

Research limitations/implications

The existing financial intelligence tools need to be repaired by removing the inherent limitations of the tools.

Practical implications

The financial intelligence units should take into cognizance the importance of early detection of terrorist financing activities for preventing terrorist attacks and need to redesign the existing tools in such a way that make these tools effective for early detection of terrorist financing activities.

Social implications

Peace will be established in society by preventing terrorist attacks through early detection of terrorist financing activities.

Originality/value

The originality of the paper lies in identifying the limitations of the existing financial intelligence tools for the early detection of terrorist financing activities.

Details

Journal of Money Laundering Control, vol. 25 no. 4
Type: Research Article
ISSN: 1368-5201

Keywords

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