Also, the BOD and Senior Management should be aware of the emerging technologies and the trends in AML and CFT.
- the key features of a robust AML reporting system including internal risk reporting and the production of Management Information (MI) and the external reporting of suspicious activity (SARs).
Some of the issues to be considered before implementing an AML reporting system are:
• Reporting lines and
• The characteristics of the reporting system such as:
1. Need for all the reports should be in written form, even if they are made in verbal initially
2. Whether employees are asked to put their names to suspicion reports and managers & supervisors are asked to comment on these reports
3. The ways by which the MLRO regularly addresses …show more content…
Whether the MLRO advises the employees if their report has resulted in SAR being made to the authorities.
A Money Laundering Reporting or Compliance officer must be able to recognize the reporting lines for suspicious activities and transactions, build reliable reporting systems that will present enough evidence that a suspicion report was made which balances the need to encourage suspicion reports and discourage irresponsible reporting and also making the staff aware of their continuing legal obligations with respect to suspicion report.
The most efficient reporting systems are hybrid systems which allowsits employees to report directly to the MLRO and also let it be made through line managers. These managers will either support the suspicion or deny the suspicion by providing required explanations wherever applicable. It is important to keep in mind that the suspicion report must be sent to the nominated officer/MLRO without any delay even if they are commented or not by the line managers. The officer must be trustworthy and approachable so that the employees can approach them easily.
The below mentioned issues should be considered in external reporting:
- Within any suspicion report, only the relevant information should be shared to the local …show more content…
The project management process between major business unit stakeholders and the IT departments should be closely involved for the successful implementation. The responsibilities for reviewing, investigating and reporting details of alerts should be clearly allocated to people having adequate skills required and should be undergone appropriate operational control and quality assurance processes. All transfers and firms should set exception procedures, which tell the supervisors of recent unusual transactions for their review. All monitoring processes should be regularly reviewed and managed so as to fight financial crimes and terrorism. The MI quality should be reliable enough to be prepared for emergency risks, as poor MI would lead to bribery, money laundering and greater corruption