Reporting Forms

Introduction

The Anti-Money Laundering and Counter-Terrorist Financing Act 2015 (AML/CTF Act) imposes ongoing reporting obligations on financial institutions.

Background

Ongoing reporting obligations

Reporting obligations are a mandatory requirement under Division 3 of the AML/CTF Act. There are three types of transaction reports that reporting entities will be required to submit to the Financial Analysis and Supervision Unit (FASU):

1. Threshold Transaction Report (TTR)                                                                

A financial institution must report a transaction in cash or in the form of a bearer negotiable instrument for K20,000 or more, whether conducted as a single transaction or two or more transactions that appear to be linked. This must be reported as soon as is practical or within maximum 10 working days from the date of the transaction (or date of the last transaction where there are two or more linked transactions). (download TTR Form)

2. International Electronic Funds Transfer Report (IEFT)

A financial institution must report an international electronic funds transfer of K20,000 or more, whether carried out as a single transaction or two or more transactions that appear to be linked. This must be reported as soon as is practical or within maximum 10 working days from the date of the transaction (or date of the last transaction where there are two or more linked transactions).  (download IEFT Form)

3. Suspicious Matter Report (SMR)                                                                       

A financial institution must report suspicious matters as soon as is practicable or within maximum 5 working days. This applies where a financial institution has reasonable grounds to suspect that information known to it may:

• be relevant to the detection, investigation or prosecution of a person for money laundering, terrorist financing, or an offence under section 15 or 16 of the UN Financial Sanctions Act 2015;
• be relevant to the detection, investigation or prosecution of a person for a foreign indictable offence; or
• concern criminal property.

It is an offence to intentionally or recklessly fail to comply with these reporting requirements. It is also on offence to provide false or misleading information or reports. (download SMR Form)