Annex 1. Indicative Examples of Insufficient STR and SAR Narratives
Effective from 7/6/2021Example 1:
| • | Reason for reporting: Statements show large payments to luxury car companies. High amounts of funds transfers continue over several months. | |||
Comments: The narrative lacks identifying information on the STR subject (name, occupation, address, account number, etc.), and no explanation is given as to why the LFI considers this activity suspicious. The narrative lacks specific transaction data that identifies the dates and amounts of the large payments and specific details on the destination of the funds (the name, location, bank, and account number of the beneficiary car companies, if identifiable).
Example 2:
| • | Money orders were purchased on 03-28-21 to ABC Corporation in the amount of AED30,000. | |||
Comments: No explanation is given as to why the MVTS considers this activity suspicious. The LFI does not indicate if money orders were purchased with cash. The LFI does not provide any information about the purchaser or nature of the business (ABC Corporation) and if this activity was normal or unusual for the purchaser or the business.
Example 3:
| • | Mr. X was the originator of 12 wires totaling AED400,000. All of the wires were remitted to a Hong Kong based company. During the same period of time, Mr. X deposited cash into his account. | |||
Comments: The narrative lacks specific details on the destination of the funds (the name of the Hong Kong based company, bank, and account number of the beneficiary, if identifiable). The depository LFI fails to include any information concerning the relationship, if any, between the LFI and the customer. Also, no specific transaction data is provided that identifies the dates and amounts of each wire transfer and the cash deposit.
Example 4:
| • | The reason for the suspicion is due to multiple third-party transfers being paid into Mr. Y account that were soon followed by multiple cash withdrawals. Funds sent from the account to multiple third parties. | |||
Comments: The narrative lacks specific details on the source of the funds (the individual/entity sending the multiple third-party transfers). The STR does not provide a timeframe of when the transfers were made, the number and value of the third-party transfers, the number and value of the cash withdrawals, and the timeframe (how soon) the cash withdrawals were made following the third-party transfers. The depository LFI fails to include any information concerning the relationship, if any, between the individual/entity sending the multiple third-party transfers and the customer.
Example 5:
| • | Information has come to our attention that the Mrs. Y has been convicted of a drug trafficking offense. | |||
Comments: The narrative fails to describe the depository LFI’s relationship with the subject and include additional identifying details about the subject (name, occupation, address, account number, etc.). The narrative does not describe any suspicious activity aside from the conviction and fails to state if the suspicion is related to money laundering or if there are possible links to the financing of terrorism and illegal organisations.
Example 6:
| • | Mrs. Y came into the bank and asked questions during the account opening process that were suspicious. | |||
Comments: The narrative does not describe the suspicious activity in detail as a basis for filing the SAR (e.g., the customer refusing to answer account opening questions; providing falsified or counterfeit documentation; exhibiting reluctance to provide detailed information about the customer’s business). The narrative template also fails to describe information that the LFI was able to gather on the prospective customer during account opening (occupation, address, etc.).
Example 7:
| • | Mr. LMN was the subject of adverse media involving his association with a terrorist group. | |||
Comments: The narrative fails to describe the depository LFI’s relationship with the subject and include additional identifying details about the subject (name, occupation, address, account number, etc.). The narrative template also does not identify the terrorist group, describe the customer’s relationship with the terrorist group, the timeframe for the customer’s involvement with the terrorist group, and how the LFI became aware of this association, such as a hyperlink to the adverse media report.
Example 8:
| • | Mrs. ABC purchased an insurance product using unusual payment methods. Mrs. ABC is a teacher at Happy Day Elementary School in Dubai and resides at 11111 Street Name, Dubai, UAE. Mrs. ABC also has two motor vehicles insured with the LFI since April 2019. | |||
Comments: The narrative fails to describe the type of insurance product purchased, on what date, with what payment method, and why the institution considers this payment method unusual. The institution also does not indicate the customer’s stated purpose for purchasing the insurance product and if this is line with what the LFI knows about the customer.
Example 9:
| • | Mr. XYZ requests to increase payments on his life insurance policy during the period from 02-01- 21 to 05-01-21, and the payments appear to be excessive, given Mr. XYZ’s prior history. | |||
Comments: The narrative fails to include additional identifying details about the subject (name, occupation, address, etc.). The narrative lacks specific transaction data that identifies the dates, amounts, and method of payment on the life insurance policy. The narrative also does not describe why the institution considers these payments to be excessive based on the customer’s prior history of payments. The narrative does not indicate how long the subject has been in possession of the life insurance policy.