adminFinancial institutions are required to meet various reporting obligations, and these include:
Suspicious transaction reporting
Securities Market Intermediaries (SMIs) should submit suspicious transaction reports to the Financial Intelligence Unit (FIU) when there is reasonable ground to believe that a transaction is linked to money laundering and financing of terrorism. Nil returns should be submitted on a monthly basis to the FIU in the case that there is no suspicion.
The Compliance Officer should receive and analyse suspicious transaction reports submitted by employees for further submission to the FIU.
When filing suspicious transaction reports, SMIs should not, under any circumstances, notify a client that his /her behaviour has been reported as suspicious to authorities, as this would constitute tipping off, a breach of the Money Laundering and Proceeds of Crime Act.
Large cash transaction reports. Large cash transaction reports should be submitted to the FIU by all SMIs who handle cash.
Single cash transaction or the sum of multiple transactions from the same account on the same day, exceeding the level determined by FIU, should be reported. Nil returns should be sent on a monthly basis if there are no such transactions.
UNSCR reporting
United Nations Security Council Resolution (UNSCR) reporting should be conducted to aid in the national fight against terrorism financing.
SMIs must screen their clients against the UN sanctions lists at onboarding, before executing a transaction on a client’s behalf, and each time there is an update on the sanctions list.
Upon receipt of a Directive, SMIs must confirm receipt and check whether they hold any assets or funds of the listed person.
If any funds are identified, they are to be frozen immediately and reported to the FIU. SMIs must maintain a sanctions monitoring register as evidence that they are continuously logging on to the UN website and checking for updates on the sanctions list.
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