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EU- SARS/STRs - How useful are they when ONLY 1.1% of the criminal profits are confiscated.


Jersey operates a SUSPICIOUS ACTIVITY REPORTING regime rather than suspicious transaction. The main difference between the two is the object of suspicion.

  • SARs focus on the activity and whether that is suspicious.
  • STRs focus on actual transactions.

It is noted that the filing of a SAR is not demonstrative of ML in itself, only that a suspicion had arisen. This aligned with the data from the 2021 Europol report, From Suspicion to Action, which found

  • That only 10% of suspicious transaction reports 16 led to further investigation.

Further It is alarming to consider, that even where further investigated, the likelihood of successful asset recovery is low. Europol findings show that from 2010 to 2014,



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