SARs IN ACTION Issue 8 - November 2020 @NCA_UKFIU www.nca.gov.uk SARs Annual Report Page 4 County Lines Page 12 SARs Exploitation Team Page 8 Law enforcement and SARs exploitation Page 6 A United Kingdom Financial Intelligence Unit (UKFIU) publication aimed at all stakeholders in the Suspicious Activity Reports (SARs) regime SARs In Action Message from the CONTENTS head of the UKFIU UKFIU updates 3 SARs Annual Report 4 Ian Mynot Digital communications 5 Welcome to the eighth edition of the UKFIU magazine. In this issue LEA SAR exploitation 6 we focus on law enforcement agencies SARs Exploitation Team 8 and their exploitation of SARs data. We A force’s perspective 10 hear from the recently formed UKFIU SARs tactical coordinator 11 SARs Exploitation Team and its efforts to support end users, while also looking County Lines 12 to educate other areas of the law enforcement community as to the value of the information in SARs. Who is this magazine aimed at? We look at how SARs are being used to • All law enforcement; this help fight County Lines criminality and includes senior investigating the work of the National County Lines officers, front-line police Coordination Centre, which has a officers and police staff dedicated financial team working to • Reporters improve our understanding of illicit • Regulators finance flows and identify opportunities to • Supervisors take action. • Trade bodies • Government partners We also hear from Ali Peacock, from the • International partners Regional Organised Crime Unit (ROCU) network, and who is the National SARs Tactical Coordinator on the new SARs We’d love to hear what you think of Intelligence Development teams which the publication, what topics you’d like have been formed to hit serious and us to consider and we’re always open organised criminals where it hurts the for possible articles/collaborations. most – their money and assets. Previous issues of this magazine are All of the topics in this issue link in available on the NCA website. nicely with the latest UKFIU podcast now available online. This podcast, the third in Please send any feedback to our series, speaks to panellists from the [email protected] law enforcement community about the value of SARs and the myriad ways they Updates can also be found on Twitter can be used to tackle all forms of crime. at NCA_UKFIU and via our LinkedIn Details of the podcast, and the rest of the page. UKFIU’s current digital communications and engagement work, is also explored in Opinions expressed in articles this magazine. provided by partners are not necessarily the view of the UKFIU/ The 2020 SARs Annual Report has also NCA. The UKFIU exercises the right to been published. We look at some of the edit submitted articles. headline figures and statistics from this on page 4 of this issue. 2 SARs In Action UKFIU updates Support on European project Legal sector virtual roundtable The UKFIU agreed to support a In August the UKFIU took part in law enforcement agency (LEA) in a legal sector virtual roundtable service of the European Money Mule event chaired by the Law Society of Action (EMMA) project, an initiative England and Wales and attended by a targeting money mules across Europe. number of solicitor firms to promote A process was established with the discussion and share knowledge. The LEA for SAR-derived intelligence of UKFIU provided guidance on better relevance to the EMMA project to be quality submissions and delivered best provided to the UKFIU for review, practice along with good news stories authorisation and dissemination regarding legal sector contributions. to European Union partners in an efficient and effective manner to The UKFIU’s signpost document target and combat suspected money (indicating our products and upcoming mule cases in the UK. events) was shared along with a SAR Online video on how to submit a good quality Defence Against Money Laundering (DAML) SAR. UKFIU core UNODC webinar messages including clarification on new glossary codes and the future The UKFIU delivered a video use of webinars, podcasts and virtual presentation at a three day virtual workshops were also discussed. webinar hosted by the United Nations Office on Drugs and Crime, which included participants from overseas Accountancy Affinity Group government authorities. The objective was to strengthen the capacity of The UKFIU contributed to the FIUs, LEAs and prosecutor offices in Accountancy Affinity SAR Group relation to financial investigations, meeting in August. Topics covered in particular concerning human included SARs IT Transformation and trafficking and organised immigration trends and patterns/case studies crime. The UKFIU shared its reflecting the impact of COVID-19. experiences in raising awareness and Feedback from the NCA Cross Sector providing modern slavery/human Forum was shared highlighting trafficking (MSHT) guidance to SAR the top three areas of interest – reporters. The collaborative work terrorist financing, modern slavery/ between the NCA’s Modern Slavery human trafficking and child sexual and Human Trafficking Unit and UKFIU exploitation. was illustrated through their support of Project Aidant (a UK wide action The UKFIU will use its social media against all forms of MSHT). The link pages (Twitter and LinkedIn) to relay between SARs and the provision other messages including signposting of investigative opportunities was to guidance documents and future reinforced by a high level description engagement events. of Project Aidant’s successes. 3 SARs In Action SARs Annual Report 2020 The 2020 SARs Annual Report has been published and is now available on the NCA website. The report highlights the value that the regime continues to bring to tackling money laundering and terrorist financing. The UKFIU continued to see a record number of SARs, receiving and processing 573,085, with an 80.67% increase in defence requests (62,408). In the face of these increases, £171,986,930 was denied to criminals as a result of DAML requests – up 30.62% on the previous year’s £131,667,477. This is where law enforcement obtained restraint or used civil powers under the Criminal Finances Act 2017 to freeze an account. An additional £50,623 was restrained or forfeited following interventions arising from refused Defence Against Terrorist Financing (DATF) requests. There continued to be a large increase in the number of SARs assessed by the UKFIU and fast-tracked to law in March 2020 the UKFIU began enforcement agencies, thereby ensuring producing a regular bulletin outlining that the maximum value of SARs the themes and trends relating to intelligence is exploited. Over the year COVID 19-related crime, drawn from the UKFIU expedited the dissemination our analysis of SAR reporting. This of 11,406 vulnerable person SARs, up has enabled collaboration with law 41.56% on the previous year. enforcement, reporters and government departments to combat harmful crime There were also 1,897 SARs pro- and raise awareness. actively identified and disseminated to the Counter Terrorism Policing This year the UKFIU has also focused (CTP) network. This process involved on international work and analysis, for the targeted review of 23,303 SARs, the first time co-leading on an Egmont identified from all SARs received. Group project. The project was co-led with AUSTRAC (the Australian FIU) and Analytical output this year increased the Anti-Money Laundering Council (the in quantity and impact. The UKFIU Philippines FIU) and focused on the delivered an increase in operational financial flows associated with online intelligence development and a greater child exploitation and abuse. This has cross matching of SARs, providing value been covered extensively in previous to law enforcement teams. For example, editions of this magazine. 4 SARs In Action UKFIU digital communications In line with the National Police Chief ‘Four P’ programme, promoting UKFIU Council’s 2025 vision relating to the good guidance, red flag indicators etc. changing risks and opportunities of (The ‘Four P’ approach to tackling serious the digital world, there has been a organised crime includes Prepare, recognised need for the UKFIU to adapt Prevent, Pursue and Protect). and promote its online presence. By building and maintaining our Since Spring 2020 the UKFIU has podcast and webinar facility, promoted been creating its own podcasts (the extensively on social media using the first in the NCA) and hosting its own UKFIU and NCA’s own channels, the webinars, aimed at improving the UKFIU has been able to target, as well as quality of SARs, promoting the work of the major reporters, the small, hard to the UKFIU and the value of the SARs reach firms, the one person businesses, regime, and providing guidance to all solicitors and estate agents etc. which stakeholders in the regime i.e. reporters, physically, due to resources and location, regulators/supervisors/trade bodies, are impossible to fully reach. These are law enforcement agencies, international likely to be the most vulnerable to money partners, government partners and the laundering. general public. Such technological capabilities are This has enabled the UKFIU to leading to improved UKFIU visibility, embrace the rapid development of awareness and sharing of knowledge and technology, adapt to the new threats best practice, driving up the standard and opportunities it presents for 21st of the reports. This has been evidenced century law enforcement and improve by the increase in traffic on the UKFIU UKFIU capabilities in step with our law Twitter