Under FATF Recommendation 25 and the Egmont Group Best Practice Guidelines, the issue of feedback from a jurisdiction’s FIU to Financial Services Businesses on the disclosure reports they submit is outlined in significant detail. Following a review of FIS feedback practices, two specific feedback initiatives were commenced in 2006.

Industry Focus Groups
Firstly, a small ‘focus’ group was formed with representatives from the main financial services sectors in order to enable informal discussion with members of the FIS and to give MLROs the opportunity to refer issues of interest. The meetings have proved very productive, with the FIS being able to receive first hand the opinions and observations of the group on issues surrounding the making of reports and the implications of anti money laundering procedures. Subjects such as tax evasion, feedback, post disclosure activity and future legislative changes have been discussed.

Feedback Project
Secondly, a review of all disclosure reports received during an agreed 12month period was conducted by FIS personnel in order to provide case specific feedback to financial institutions. This took the form of written feedback outlining the disclosure, a brief description of any relevant developments since the report was made, such as whether or not the intelligence was disseminated to another agency or jurisdiction, any follow-up assistance requested and any specific outcomes resulting from the information the institution provided.

Commencing with all reports received during 2004, a total of 591 disclosure reports from 120 different financial services businesses were reviewed and following evaluation, the FIS concluded that in light of the positive response from industry, the project will be repeated annually.