Only the appointed compliance officer has the sole discretion and independence to evaluate and report suspicious transactions to FIED, BNM.

In this regard, the reporting institution must ensure that the appointed compliance officer has the sufficient stature, authority and seniority within the reporting institution to be able to make effective AML/CFT related decisions, including STR submission.

There is no threshold for reporting of suspicious transaction. It is based on any suspicion that arises when establishing business relationship or conducting a transaction regardless of any amount. However, a reporting institution may set an internal threshold based on the reporting institution’s own risk assessment.

As per paragraph 19.2.10 of the Policy Document, where an STR has been lodged, reporting institutions may opt to update or make a fresh STR as and when a new suspicion arises.

Reporting institutions are encouraged to submit a new STR if there is new critical information. Where a new STR is submitted, reporting institutions should include the previous reference number (or date of submission, if submitted manually) as part of the reporting description.

These reports and supporting documents are to be kept for at least 6 years, as specified under the Record Keeping requirements in paragraph 21.3 of the Policy Document.

Reporting institution must ensure that any internal STRs and supporting documents or records must be made available to the relevant supervisory authorities upon request, as required under paragraph 19.4.2 of the Policy Document. The information must be maintained in a form that is admissible as evidence in court pursuant to the Evidence Act 1950.