(8) Investigation and Reporting of Suspicious Transaction
“Suspicious transaction means a transaction with reasonable grounds to believe that it is conducted to avoid the application of the law, or transaction connected or possibly connected with the commission of a predicate offense or terrorist financing offense, notwithstanding the transaction being single or multiple and shall include an attempt to conduct such a transaction” (please refer to the AML/CFT Manual on 3.1 Suspicious Activity Investigation Process and Appendix II – Suspicious Activity Report Guideline). Therefore, they are required to be reported to AMLO, as stated in Section 13 and Section 16 of AMLA and Section 5 and Section 6 of Counter-Terrorism Financing Act.
It is the business units’ responsibility to make their staff aware of money laundering issues, and to be vigilant at all times where suspicious transactions are concerned.
When a suspicious transaction or a suspicious customer id detected, staff must not inform the customer. The proper practice is that staff should alert his immediate supervisor/AML Officer and Compliance Officer for taking promptly reasonable steps to assess the background of the account or transaction.
Business/support units should have an effective system (whether computerized or manual ) and procedures for reporting internally and externally to regulators on unusual or suspicious patterns of activity in the customer’s accounts.
(8) Investigation and Reporting of Suspicious Transaction“Suspicious transaction means a transaction with reasonable grounds to believe that it is conducted to avoid the application of the law, or transaction connected or possibly connected with the commission of a predicate offense or terrorist financing offense, notwithstanding the transaction being single or multiple and shall include an attempt to conduct such a transaction” (please refer to the AML/CFT Manual on 3.1 Suspicious Activity Investigation Process and Appendix II – Suspicious Activity Report Guideline). Therefore, they are required to be reported to AMLO, as stated in Section 13 and Section 16 of AMLA and Section 5 and Section 6 of Counter-Terrorism Financing Act.It is the business units’ responsibility to make their staff aware of money laundering issues, and to be vigilant at all times where suspicious transactions are concerned.When a suspicious transaction or a suspicious customer id detected, staff must not inform the customer. The proper practice is that staff should alert his immediate supervisor/AML Officer and Compliance Officer for taking promptly reasonable steps to assess the background of the account or transaction.Business/support units should have an effective system (whether computerized or manual ) and procedures for reporting internally and externally to regulators on unusual or suspicious patterns of activity in the customer’s accounts.
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