How do identify a Suspicion?
An effective systemic approach to identify suspicious financial activity may safeguard you and your institution, business or profession from the risk of being involved with terrorist financing and money laundering crimes. Consider the “SAFE” approach which may assist you in legal compliance and staff training.
Examination of the STR's received by JFIU reveals that many reporting institutions do not use the system outlined above. Commonly, institutions make a STR merely because a suspicious activity indicator has been recognized, i.e. only step (1) of the systemic approach is followed, steps (2), (3) and (4) are not followed. This failure to use the systemic approach leads to a lower quality of STRs.
Each of the four steps of the systemic approach to suspicious activity identification are discussed in more detail in the following paragraphs.
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| Evaluate all the above information : Is The Transaction Suspicious? |
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The final step in the suspicious activity identification system is the decision whether or not to make a STR. Due to the fact that suspicion is difficult to quantify, it is not possible to give exact guidelines on the circumstances in which a STR should, or should not, be made. However, such a decision will be of the highest quality when all the relevant circumstances are known to, and considered by, the decision maker, i.e. when all three of the preceding steps in the suspicious transaction identification system have been completed and are considered. If, having considered all the circumstances, staff find the activity genuinely suspicious then an STR should be made.
Staff will seldom, if ever, encounter a situation in which a customer carries out apparently suspicious activity which they have reason to suspect is linked to a specific crime or type of crime. Institutions, Businesses or Professions are therefore encouraged to make suspicious transaction reports in circumstances where, although they do not know which specific crime or type of crime is connected to the suspicious transaction, there are one or more suspicious activity indicators present, together with an inability or unwillingness on the part of the customer to give a reasonable and legitimate explanation and inconsistency between the financial activity undertaken and that which is to be expected from the customer. |
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