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Suspicious Transaction Reporting
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Suspicious Transaction Reporting
Training for Junior Compliance Officers - 13 December 2017
Case Study
How can the STR be improved?
Case Study
Mr Ang is a 33-year-old Engineer. During a review of his account activity, it was observed that there were incoming funds from several unidentified third parties. These funds were eventually remitted to various other unidentified parties. A Request for Information was performed where customer was contacted but unwilling to provide details. Given the rapid fund movements and customer’s unwillingness to provide information regarding the fund transfers, this STR has been lodged.
Lodging on STROLLS
STRs can be lodged online via the Suspicious Transaction Reporting Online Lodging System (STROLLS)
Lodging on STROLLS
- An account has to be created before users can access STROLLS through the use of their Singpass.
- Details and supporting documents are to be uploaded
- STR will only be lodged successfully upon approval by the designated approving officer
Detailing STRs
STRs should provide clear, concise, meaningful information in a chronological order.
Detailing STRs
Supporting documents such as photo identification of the subject and statements must be provided as well.
Timeframe
Timeframe
- STRs must be lodged within 15 days from the discovery of the suspicion, unless circumstances are exceptional or extraordinary.
- Banks must also exercise care in potential 'tipping off' when taking steps to Request For Information or exiting the Banking relationship.
Regulatory Obligations
i) FATF Recommendation 20
- Reporting of all criminal acts that would constitute a predicate offence (i.e. money laundering, terrorist financing)
- Mandatory obligation
- Reports should be made regardless of amount
Regulatory Obligations
ii) Corruption, Drug Trafficking & Other Serious Crimes (Confiscation of Benefits) Act (CDSA)
- Establishment of STRO to receive and analyse reports
- Disclosure not considered a breach, and person shall not be liable for any loss
iii) MAS Notices 641 & 626
- Lodging of STRs to STROs (for money laundering and terrorist financing)
- Designated reference point within organisation
- Record-keeping
Statistics
Statistics
CAD Annual Report 2016
Last year saw an increase of 11.9% of STRs lodged; demonstrating the increased vigilance and awareness of money laundering and terrorist financing across various sectors.
Majority of STRs lodged in 2016 originate from the banking sector, as with in past years as well.
Source: Commercial Affairs Department Annual Report 2016
Reports
STRs lodged are reviewed and analysed by the STRO and may potentially lead to the prosecution or conviction for the crime.
Reports
Examples:
- 2016 - Three individuals were convicted for the falsification of accounts and money laundering offences amounting more than USD2 million. The investigation arose from an STR lodged in 2010.
- 2013 - An individual was sentenced 9 months of jail-time for assisting in money laundering through the transfer of funds for an overseas fraudster
Source: The Straits Times, 09 October 2017
Suspicious Transaction Report (STR)
A report made on the basis of reasonable suspicion where any property is directly or indirectly connected to criminal conduct.
Suspicious Transaction Report (STR)
It is lodged with the Suspicious Transaction Reporting Office (STRO) of the Commercial Affairs Department (CAD) - an investigative agency under the Singapore Police Force (SPF).
Everyone can lodge an STR provided they have a reason to suspect, or has possession of property of information relating to the crime.
Scenarios (non-exhaustive)
Scenarios (non-exhaustive)
Transactions that:
- Do not make economic sense
- Involve large amounts of cash
- Involve transfers abroad
- Involve unidentified third parties
- Not aligned to nature of business
- Refusal to disclose information
Learning objectives
- What is a Suspicious Transaction Report (STR)?
- Regulatory obligations, Statistics, Reports
- Detailing STRs & timeframe
- Lodging on STROLLS
- Case studies
- Questions & Answer