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2.3STR Decission Making
2.3STR Decission Making
M A Islam, CAMS, CDCS, CSDG Compliance Route Mob : 01953587666 & 01732646139
STR Decision-Making Process
FILING AN STR
QUALITY ASSURANCE
M A Islam, CAMS, CDCS, CSDG Compliance Route Mob : 01953587666 & 01732646139
STR Decision-Making Process
STR The decision of whether or not to file a STR often involves weighing the
aggravating and mitigating factors arising from the research conducted
during the investigative process.
Aggravating factors
Mitigating factors
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STR
STR Decision-Making Process
Escalating their
findings to a compliance officer,
manager, or other staff
Investigating Officer member with authority to make
the filing decision.
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STR
The final decision should be documented and supported by the reasoning that
was used to make the determination.
Oftentimes, the reason not to file a STR maintains a similar level of importance
as the reason to file a STR.
After the decision to file has been made, the institution should report the activity
to their regulatory agency, law enforcement, or both as defined by the applicable
regulations within their jurisdiction.
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STR
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STR
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STR
Client base
Product offerings
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STR
The recipient of the STR does not have the intimate knowledge of
what is expected activity for a particular institutions clients and
products, and will only stand to benefit from the inclusion of this
information.
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STR
▓ If, following the investigation, the institution decides that it should file a STR; it should
notify the investigators or prosecutors as soon as possible. However, this may not be
practical in certain jurisdictions.
But Why ?
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STR
The AML/CFT officer or designee should keep the management and board
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QUALITY ASSURANCE
All FI are required to file timely and complete STRs
The quality of the STRs can be an indication of the quality of a FI’s AML/CFT
program.
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I. that,
STR FILING OVERSIGHT/ESCALATION
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Based on its internal investigation, the FI should make an independent determination as
to whether to close the account in issue.
2 The institution’s stated policies and procedures for closing an account, which
may include automatic closure recommendation following a specified number of
STR filings
The seriousness of the underlying conduct. If the conduct rises to the level
3 where the account would ordinarily be closed, then the institution should
consider closing the account
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Legal basis
Considering
Factors Underlying conduct
Reputational risk
Requests : law
enforcement
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When an institution files an STR, the details of that filing may rise to the level
that warrants additional law enforcement notification.
Therefore, it is critical each institution develop its own policy and procedures for
communicating with law enforcement regarding STRs.
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Communicating with Law Enforcement on STRs
Following the filing of the STR, the responsible compliance officer or designee may
decide to contact a particular law enforcement division to notify them of the recent
filing to make them aware of activity relevant to their area of coverage or
geographical location.
Moreover, a law enforcement agent may contact the FI that filed the STR seeking
the underlying information used in the investigation that resulted in the STR.
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