BIBA response to Home Office consultation paper – tackling money laundering suspicious activity reports: prescribed form and manner

22nd October 2007

The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance intermediary organisation. We represent the interests of insurance brokers, intermediaries and their customers.

BIBA represents 2,300 insurance intermediaries including 98 of the UK’s top 100 insurance intermediaries. Our members handle about half the value of all UK home, contents, motor, travel, commercial and industrial insurance policies. Independent insurance intermediaries distribute nearly two-thirds of all UK non-marine general insurance, of which BIBA members account for over 80%. They also introduce £20 billion of premium income into the UK insurance market each year.

BIBA is pleased to have the opportunity to respond to the Home Office consultation, entitled ‘ tackling money laundering suspicious activity reports: prescribed form and manner’, on behalf of its collective membership.

Our responses to the six questions set out are as follows:

  1. Do you agree with the proposals to prescribe the manner in which SARs must be made? If not, please explain why.
    Overall, yes, we think this a sensible measure and should improve the speed and efficiency with which reports are filed by firms and accessed by SOCA. However, we do have concerns about how people will be treated if they do not have all the requisite information to fill in mandatory elements of the forms properly.

  2. Is it reasonable and proportionate to expect hard copy submissions to be typed?
    No, to encourage reporting and reduce ‘barriers’ we do not believe it is reasonable to insist on typed submissions. If we are to reduce crime, reporting must be as easy as possible. Smaller firms, in particular may not have the resources to get these forms typed up. This may delay filings.

  3. Is the cost of implementing a prescribed form and manner of reporting proportionate to your firm/sector? If you believe the cost to be dis-proportionate please explain why and provide details of the cost.
    There will be cost implications to those firms that do not have the necessary software to access the forms, but we do not think the cost is disproportionate.

  4. 2. Do the proposals provide sufficient options for your firm/sector to make SARs? If not, please explain why and give examples of additional methods which you would wish to use.
    Yes. The proposals provide sufficient options to suit all firms depending on their size, the complexity of their business and the technology that they have access to.

  5. Does this document sufficiently reflect the benefits to your firm/sector? If you have additional comments on this section, please provide them in your response.
    Yes, but some of the forms and their terminology may look quite daunting and confusing for a small insurance broker who may not have seen these documents before e.g. ‘existing disclosure ID’, ‘FIU reference’, ‘associated disclosure reason’ etc. We suggest that the introduction of any forms is accompanied by detailed notes explaining how to fill the forms in.

  6. Do you think the additional proposals of raising awareness of what constitutes a ‘required’ disclosure’ is necessary/critical to the effective implementation of a prescribed form and manner?
    We believe that there is insufficient awareness about SOCA and its role among smaller general insurance intermediaries. It would be beneficial to increase awareness about SOCA as well the responsibilities on general insurance intermediaries to ensure that their businesses are not being targeted for the purposes of financial crime. We therefore think it important that measures to raise awareness of what constitutes a ‘required’ disclosure is necessary to ensure the effective implementation of SARs reporting in a prescribed form and manner.

Thank you for taking the time to consider our response. If you have any further queries please contact BIBA’s Technical Services Manager Graeme Trudgill for further information on 02073970218 or [email protected].

Yours sincerely

Eric Galbraith

Chief Executive
Direct Tel: 020 7397 0201
Direct Fax: 020 7626 9676

Email: [email protected]