Internal Reporting for AML

AML Reporting Overview

The success of our Anti Money Laundering program depends on you! We have implemented an AML program by developing internal policies, procedures, and controls. Aside from escalating any red flags, you also need to record any issues appropriately.

  •  Keep correct records.
  •  Monitor and investigate transactions for suspicious activity and to ensure they are within legal thresholds.
  •  Report transactions in line with our policy and the regulations. You can find out who to report to here.
  •  Find out what our AML policy and internal controls expect from you.
  •  Ask for help if you need it.

Our policy contains rules on when and how to report breaches and suspicions, what records to keep, and how to ensure you know who you are dealing with.

It includes:

  •  Reporting tools
  •  Escalation channels
    If you are unfamiliar with any of these rules, you can find out who to contact for advice or to report issues here.

We have a Customer Identification Program (CIP) in place. This program – often called Know Your Customer (KYC) – defines procedures to document and verify the identity of clients. Do you know our CIP procedures? If not, please learn about them. If you have any questions, find out who to contact here.

Currency Transaction Reports (CTRs) are filed EVERY TIME any one person conducts more than $10,000 (daily aggregate) in CTRs provide a paper trail for otherwise invisible transactions – making it difficult for criminals to place cash into the banking system. Check out our policy around how and when to file CTRs. You can find out who to contact with any questions here.

A Suspicious Activity Report (SAR) must be filed for certain transactions and harsh penalties apply if we don’t.

A SAR must be filed for any transaction over $2,000 if there is a reasonable suspicion that it:

  •  Involves funds that are illegally acquired.
  •  Is structured to avoid traceability.
  •  Has no apparent business or lawful purpose.
  •  Is based on false information.
  • ever let a client know you are filing a SAR unless you are instructed to do so in writing by our General Counsel!

AML laws define the records we must keep and how long they must be kept. Following our record-keeping and reporting procedures will help protect us in the event of an investigation by the authorities.

  • AML records – keep for 5 years
  • CIP records – keep for 5 years from date account closes
  • Depending on your role, you may have specific reporting requirements. Check our AML policy for YOUR reporting requirements. You can find out who to contact with any questions here.

A client contacts Pamela and asks her to transfer $9,750 from their account to five offshore accounts that the client hasn’t used before. The transactions total $48,750.

Which four actions should Pamela take?

  •  Check the AML policy.
  •  Collect identification data from the client.
  •  File a Currency Transaction Report (CTR).
  •  Refuse to complete the transactions.
  •  File a Suspicious Activity Report (SAR).

Currency Transaction Reports (CTRs) are filed EVERY TIME any one person conducts more than $10,000 (daily aggregate) in cash transactions into or out of a single account, or when a series of related transactions over a 12-month period totals more than $10,000. Pamela must collect customer identification as part of the Customer Identification Program (CIP) and also file a CTR. Because the five transactions just below the $10,000 threshold are suspicious, Pamela should file a Suspicious Activity Report. Pamela shouldn’t refuse the transaction, as this will alert the client to her suspicions.

  • We have AML internal reporting requirements. You can find out what they are here. You must follow them at all times.
  • You may need to file Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs).
  • If we have suspicions, we never tip off the client.

This content is an extract from the anti money laundering course.

Download our Anti Money Laundering booklet.
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