Staff will submit a written internal Suspicious Activity Report or Suspicious Transaction Report (SAR/STR) to the Compliance Officer.
After an internal SAR/STR is submitted to the Compliance Officer(CO) , and the CO determines whether the SAR/STR should be submitted to the FIU.
The FIU cannot speculate the criminal offence it must be explicitly stated.
The internal SAR is a version of the FIU’s SAR/STR template, it is usually a form contained in the Compliance Program.
The Compliance Officer relies on the in the internal SAR so the intelligence provided by frontline staff is crucial.Intelligence goes from employee to the Compliance Officer, then Compliance Officer to the Financial Intelligence Unit.
About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.
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