In 2014, MROS received the highest level of reporting volume since its inception. With a total of 1,753 SARs, this exceeded the 2011 level of 1,625 SARs ‒ the largest reporting volume until now ‒ by more than 100 reports.
More than 85% of total reporting volume came from the banking sector. While reporting volume from this sector rose from 1,123 SARs in 2013 to 1,495 SARs in 2014 ‒ an increase of 33% ‒ the number of SARs from other financial sectors declined, most notably from fiduciaries and asset managers.
Total asset value rises
The total asset value of reporting volume increased by 12%, to more than CHF 3.3 billion. One SAR involved assets of more than CHF 200 million, while six other SARs involved assets of over CHF 75 million. Together these seven SARs made up approximately one third of total asset value.
At CHF 2.85 million, the amount of assets involved in SARs forwarded to the prosecution authorities was comparable to 2013 (CHF 2.8 million).
Predicate offences: twofold increase in cases of suspected bribery
The number of SARs involving bribery as suspected predicate offence more than doubled. This was due, in particular, to one large and complex case that triggered over 50 SARs. The case was forwarded to the prosecution authorities for further investigation.
As in previous years, fraud was again the most frequently reported predicate offence to money laundering, with the number of SARs relating to this offence increasing over the previous reporting year (448 SARs as opposed to 373 SARs in 2013). Moreover, the number of reports involving phishing, i.e. the fraudulent misuse of a computer, remained high.
The number of SARs involving terrorist financing fell, from 33 in 2013 to 9 in 2014. However, whereas the 33 SARs in 2013 concerned 8 individual cases, all 9 SARs in 2014 related to separate cases. Hence, the situation remained comparable to the previous reporting period.
Greater analysis capacity at MROS
MROS forwarded 72% of all SARs to the prosecution authorities. This is 7% lower than in the previous reporting period and continues the falling trend of the last three years. The decline can be explained by the fact that MROS filters out more SARs that are unsubstantial, leading to an easing of the burden on public prosecutors’ offices. Under the partial revision of the Anti-Money Laundering Act, which came into force at the end of 2013, MROS has been granted additional powers to gather information from third party financial intermediaries. Moreover, MROS strengthened the co-operation with its foreign counterparts and public prosecutors. All these factors have contributed to the decrease.
Implementing the revised FATF Recommendations
On 12 December 2014, the Swiss parliament passed the Federal Act on Implementing the Revised Recommendations of the Financial Action Task Force FATF, which is expected to come into force on 1 January 2016. The new piece of legislation will have a direct impact on MROS since the reporting system will be subject to significant changes. Assets will no longer be automatically frozen on submission of a SAR to MROS, but rather when MROS informs the financial intermediary that the case has been forwarded to the prosecution authorities. Furthermore, the very short deadline for analysing SARs has been extended to a maximum of 20 days, which should further improve the quality of the analyses.
The revised legislation also extends the spectrum of predicate offences, which will include for the first time serious offences related to direct taxation. It also includes the obligation that merchants submit a SAR to MROS on receiving more than CHF 100,000 in cash for any given transaction.
Also in connection with the revised FATF Recommendations was the work which started on a National Risk Assessment (NRA) and the collection of statistical data. MROS began updating its information on the outcome of criminal investigations and proceedings on money laundering cases. The figures are presented in the 2014 Annual Report.
Last modification 28.04.2015
