Process to escalate a Suspicious Activity Report STR/SAR to Compliance Officer

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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No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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What happens after registration with the Financial Intelligence Unit (FIU) in Trinidad : Anti Money laundering Training

Thanks for stopping by!! What happens after registration with the FIU in Trinidad? I am so glad that you asked!

After you submit the RG-1 Form to register with the FIU, your certificate will be prepared and you will be contacted via call to collect same.

Please see below for your obligations post registration with the FIU:

Appoint a Compliance Officer who is competent and experienced with the Anti-Money Laundering and Countering the Financing of Terrorism laws and regulations.

After you appoint this Compliance Officer (CO), the “Fit and Proper” Form must be completed and submitted to the FIU for their approval.

An Alternative Compliance Officer (ACO) must also be appointed.

A Compliance Program must be created using a Risk Based Approach.

Know Your Customer (KYC) Forms must then be created.

All staff and directors must attend Ant-Money Laundering and Countering the Financing of Terrorism Training every year.

There must be an internal and external Anti-Money Laundering audit conducted (not a Financial Audit).

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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THE ROLE OF A COMPLIANCE OFFICER:

The Compliance Officer is the primary liaison with the FIU . The identities of the Compliance and Alternate Compliance Officers must be held with the strictest confidence.

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The duties of the Compliance Officer include:

a)Creating, monitoring and updating the AML/CFT Compliance Programme to ensure continuous compliance with the legal framework. The internal controls and policies therein must be implemented by the CO.

b)Receiving and assessing SAR/STR reports made by staff members.

c) Reporting SARs/STRs to the FIU using the Suspicious Activity/Transaction Report Form within fourteen (14) days of the suspicious transaction being detection.

d)Maintaining records of internal SARs/STRs from staff.

 e)Maintaining a register of of SARs/STRs filed with the FIU.

f)Maintaining Customer Due Diligence records and transactions;

g) Monitoring the FATF list of high risk individuals and legal entities and Non-Cooperative Countries and Territories (NCCTs).

h)Monitoring the United Nations ISIL Da’esh & Al Qaida List (UN 2253 List) for persons identified as terrorists or involved in terrorist activity.

  i)Provide training to all members of staff.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP,

Blog: https://sydneygroupblog.wordpress.com/

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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