Factors arousing suspicion

The Money Laundering Reporting Office Switzerland’s (MROS) annual report contains information about the factors arousing suspicion which lead to Suspicious Activity Reports (SARs). In 2016, 34% of the reports were based on information from the media, including data collections such as KYC records, which contain consolidated data from the media and internet (government websites). In the 2012 annual report (p.10), the MROS indicates that “the financial intermediary may submit a SAR [...] on account of a suspicion based on probability, doubt or a sense of unease about entering into a business relationship.”

The number of reports submitted voluntarily has risen continuously since 2010, and increased noticeably from 2013, after the MROS clarified its position in its 2012 annual report. We can therefore conclude that information from the media has become more important. The annual reports do not indicate whether the rate at which reports are being passed on to the criminal authorities has also risen.

Complete Revision of the Federal Data Protection Act

Complete Revision of the Federal Data Protection Act: „As of 15th September 2017, draft and report for a completely revised Federal Data Protection Act is public. In a first step parliament and the people agreed to adaptations in order to be compliant with EU law. The second part of the revision is debated by the parliament since September 2019. Data Protection is to be increased by giving people more control over their private data as well as reinforcing transparency regarding the handling of confidential data.”

Links: datenrecht.ch

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