ANNEX E
The inverted reporting cascade
An important part of a well functioning and efficient AML/CFT-system is the inverted reporting cas-
cade, meaning that from the lowest level, the cases investigated because of an unusual pattern, to the
top level, sentencing by the court, legal conditions become stricter and stricter, leading to not all un-
usual cases that are being investigated leading to the reporting of an SAR/STR, not every SAR/STR
being forwarded to prosecutors, the prosecutors then not opening criminal proceedings in all cases of
an SAR/STR, not all criminal proceedings that have been opened leading to an accusation and of
course not every accusation leading to a sentence. The picture one gets is that of a fir tree, hence the
cascade is an inverted one.
Sentences by the court — ees
Accusations brought to court ~~ 00 oM
Criminal proceedings opened =~ : ----=---=----------=---=--==- esse esse
SARS/STRS filed aaa anna
Cases investigated —-mmmm mmm mmr eoeenneeeeeceee neenon enoeene mme -m-----
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