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16.21 Suspicious Transaction Reporting

N 35/2018 STA
  1. 16.21.1Internal disclosure requirements:
    1. a)The Licensed Person must implement procedures, controls, systems and tools for its employees to internally disclose all suspected cases of money laundering or terrorist financing directly to the Compliance Officer or to an appropriate member of the compliance department without any interference from the Manager in Charge or any other employee of the Licensed Person;
    2. b)All internal disclosures must be thoroughly investigated to confirm if there are reasonable grounds for suspicion;
    3. c)If the investigation of an internal disclosure does not reveal reasonable grounds for suspicion, then the Compliance Officer may decide either to close the case or keep it open for future monitoring; and
    4. d)The Compliance Officer must retain documentary evidence regarding all internal disclosures, details of investigations undertaken and reasons for closing a case or keeping the case open for future monitoring under watch list or for reporting to the FID.
  2. 16.21.2External Reporting to the FID:
    1. a)As a primary requirement of submitting Suspicious Transaction Reports (STR), the Licensed Person must obtain access to the online STR reporting portal of the Central Bank. The Licensed Person may contact the FID or the Banking Supervision Department for appropriate guidance to obtain access to the STR reporting portal;
    2. b)The Compliance Officer must report all cases where there are reasonable grounds to suspect money laundering, terrorist financing and/or financing of illicit organizations to the FID including any attempted transactions by suspicious customers;
    3. c)Procedures and controls must be implemented to ensure timely reporting of suspected cases to the FID;
    4. d)The Licensed Person must comply with all directions of the FID in relation to STRs submitted to them;
    5. e)The Licensed Person must keep appropriate records of STRs reported to the FID; and
    6. f)The Licensed Person must freeze the funds involved in any suspicious transactions related to terrorism, terrorist organizations, foreign terrorist fighters or for terrorism purposes and immediately report to the FID without any delay.