Money laundering reporting officers (MLROs) and compliance
professionals in Guernsey's finance industry would welcome more
detailed guidance and clarity around the steps and processes
involved in lodging suspicious activity reports (SARs), according
to Carey Olsen regulatory experts Mark Dunster and Simon
Florance.
Speaking at the firm's latest regulatory conference in
Guernsey, titled 'To SAR or not to SAR – is that the
question?', Mark and Simon explained that there was a lot of
uncertainty in the minds of MLROs. This uncertainty arises around
what constitutes a valid suspicion and the time frames expected to
be met between having that suspicion and submitting a SAR to
Guernsey's Financial Intelligence Service (FIS) under the
provisions of The Disclosure (Bailiwick of Guernsey) Law, 2007.
