Article 30 Reporting suspicious transactions

(iii) Reporting of suspicious transactions?

Only 24 States require charities and other non profit organisations to report suspicious transactions.

The CTC is grateful for the detailed report on suspicious transactions (at page 13) of the fourth report.

Reporting of suspicious and or unusual transactions

1.5 Paragraph 1 of the resolution requires that the legal obligation to report suspicious transactions should extend to all professions engaged in financial transactions.

Could Thailand please confirm whether such professionals do report suspicious transactions to the Thai Financial Intelligence Unit?

To date, no suspicious transactions have been identified.

The Decree makes it obligatory to identify customers and report suspicious transactions in respect of the following activities.

Question on the requirement to report suspicious transactions by all financial institutions, as well as by insurance companies and other such intermediaries engaged in financial transactions.

New professions that were obliged to report suspicious financial transactions were accountants, lawyers and dealers in high value goods.

Currently, no specific act in Benin's legislation requires the notary or attorney to report the fraudulent origin of suspicious transactions.

c) Suspicious transactions, irrespective of the amount mentioned in this paragraph.

Are financial institutions, other intermediaries and other natural or legal persons required to report suspicious transactions to the relevant authorities? What penalties apply to those who omit to report?

The transactions stipulated in part 3 of this Article are not considered as suspicious.

States were asked to report whether measures had been adopted in their financial systems with a view to enabling the reporting of suspicious and or unusual transactions.

1.4 The effective implementation of subparagraph 1 (a) of the Resolution requires financial institutions and other intermediaries to identify their clients and to report suspicious transactions to the competent authorities.

Financial institutions have the legal obligation to urgently report transactions suspected to involve terrorist activities to AMLO as a suspicious transaction within 7 days from the date of executing the transaction.

Most transactions were reported as a result of structuring, which is the act of committing many transactions that are under the required threshold in order to avoid seeming suspicious.

Belarus intends to establish a special State entity responsible for detecting suspicious transactions and preventing the financing of terrorism.

The Netherlands' second report, in reply to question 2 (at page 3) states that the obligation to be vigilant and to report suspicious transactions will be extended to include persons practicing liberal professions such as lawyers, notaries and accountants.

1.11 The Supervision Department of the Central Bank is the body empowered to receive reports of suspicious transactions in Jordanian banks.

4.5 Exchange of information regarding suspicious financial transactions, illegal financial operations and assistance in establishing and strengthening contacts between appropriate authorities.

For example, FATF recommendations relating to customer due diligence, record keeping, suspicious transactions, anti money laundering controls policies and staff training.

As regards the reporting obligation, the CTC has noted that no convictions have been secured in Thailand for failing to report suspicious transactions and that a maximum fine of 300,000 Baht may be imposed.

In the report on suspicious transaction the grounds for the transaction to be considered suspicious should also be mentioned.

The Law of the Republic of Armenia on the Fight Against Legalizing the Illegal Income and Financing of Terrorism stipulates an obligation to report both suspicious transactions relating to the prevention of the financing of terrorism and money laundering activities and or transactions linked to other criminal activities.

The relevant national authorities are expected to provide practical guidance as to what constitutes suspicious transactions for the use of financial institutions.

It could be noted here that the criteria for suspicious transaction reporting vary from one State to another some set out a certain amount of money as the threshold for reporting, whereas others take a more generic approach, where banks are required to report transactions they think are suspicious , regardless of the amount.

Normative legal acts of the Central Bank can establish other grounds, not mentioned in this part, for considering transactions as suspicious, based on which the persons submitting the reports are bound to regard the transaction as suspicious.

(e) States should require operators of registered remittance systems to meet the same know your customer requirements as the formal banking sector, record correspondent relationships, report suspicious transactions, maintain records, and generally comply with all FATF recommendations

REQUIRED BANK REPORTING PROCEDURES suspected transactions have been reported by banks, on their volition, using the Suspicious Activity Reports (SAR) reporting procedure. These reports

For the persons licensed by the Central Bank the criteria for considering the transactions as suspicious are established by the Board of the Central Bank.

In particular, the CTC would appreciate learning the number of suspicious transactions which have been reported to the Thai Financial Intelligence Unit in recent years?

91 308 EEC on prevention of the use of the financial system for the purpose of money laundering. As a result, transactions suspicious of financing terrorist acts will undergo the same reporting and suspension system as those suspicious of money laundering.

Member countries are also encouraged to report on other crimes which may be linked to terrorism, such as suspicious financial transactions, weapons trafficking, money laundering and falsified travel and other identity documents, seizures of nuclear, chemical and biological material.

The number of suspicious transactions reported varied widely between countries and might have been influenced by differing requirements, such as whether reporting was mandatory or not.

States that had adopted measures for the reporting of suspicious or unusual transactions, by region (those responding in both the second and the third reporting periods)

In addition, the Royal Military Police, which controls and guards Dutch borders, reports any suspicious situations directly to the national police unit that analyses unusual transactions.

It is not clear, however, whether the Act extends to professionals such as lawyers. The CTC, therefore, would appreciate receiving clarification on whether lawyers and similar professionals are required under Egyptian law to report suspicious transactions to the Anti Money Laundering Unit.

(d) States should consider the adoption of measures to enable and facilitate the reporting and investigation of suspicious and or unusual transactions that may be linked to money laundering activities

The effective implementation of prior import export notification systems had enabled competent national authorities to verify the legitimacy of transactions and to identify suspicious shipments, thus preventing diversion of precursor chemicals.

Some speakers stressed the critical role played by financial intelligence units in the analysis of suspicious financial transactions and reported on the establishment or functioning of financial intelligence units in their countries.

If the answer is Yes , please specify and provide any available information on, inter alia, the criteria used for identifying suspicious transactions or the sanctions imposed for non compliance with reporting requirements.

Prevention should include promoting the use of the formal financial sector while, at the same time, ensuring control of informal transfer systems, registering financial dealers and requiring the reporting of suspicious transactions.