Demonstration: Reporting Suspicious Transactions and Persons for STR
Demonstrating the process of reporting suspicious cheque encashment and outward fund transfer transactions involving two individuals - one who encashed the cheque and the other who received funds abroad. Includes detailed person and transaction information for both instances, along with the preparation of Person and Transaction Details tables, and the submission of a Suspicious Transaction Report (STR) and a Prescribed Account Entity (PAE) report with the necessary details.
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[Limited Sharing] Submitting STR Report Demonstration 1 (P to P) Scenario a person did a suspicious encashment of a cheque and subsequently sent funds to another person abroad as an outward fund transfer Following is the breakdown of this scenario for STR reporting: There are 2 transactions to be reported: i. A person did a suspicious cheque encashment ii. Same person sent funds to another person abroad as outward remittance These two transactions contain 2 persons to be reported: i. Person who encashed the cheque ii. Person who received the funds from outward remittance Prepare PAE and transaction details tables as below (since these are person to person transactions, only person details table is required):
[Limited Sharing] Submitting STR Report Demonstration 1 (P to P) Person Details Person 1* Person 2 Suspect? Yes Yes First Name Saman Mohommad Last Name PERERA SULFI Birthdate 01/05/1980 NIC Number 800123456V Nationality Sri Lanka Residence Sri Lanka Qatar Occupation Driver Address Type Personal Address 11, Samagi Mawatha, Rajagiriya Address District Colombo *If Person 1 is a not my client , only First Name and Last Name are mandatory. But always provide all details where possible Address Country Sri Lanka
[Limited Sharing]Submitting STR Report Demonstration 1 (P to P) Transaction Details Transaction 1 Transaction 2 Transaction Number TXN001 TXN002 Transaction Mode Branch Other Trnx Mode Comment Outward remittance to Qatar Local Amount (LKR) 500,000 500,000 Date 18/08/2023 18/08/2023 Transaction Location Colombo Fort Colombo Fort Nature of Transaction Cheque encashment Outward remittance to Qatar Bi Party? Yes Yes From Party / Multi Party Person - 800123456V Person - 800123456V From Funds Code Cheque Cash From Forex Details To Funds Code Cash Cash To Forex Details 5600 Qatari Riyal @ 87/- LKR exchange rate To Party Person - 800123456V Person Mohommad SULFI Comments Encashed a cheque (number CHQ001) and informed it was a business payment receipt Sent the same amount in the encashed cheque to person and informed it was a business payment
[Limited Sharing] Submitting PAE Report Demonstration 1 (P to P) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Person 1 (Relationship: My Client) - 800123456V Person 2 (Relationship: Not My Client) Mohommad SULFI
[Limited Sharing] Submitting STR Report Demonstration 2 (P to E) Scenario a person made a suspicious outward remittance to a foreign entity Following is the breakdown of this scenario for STR reporting: There is 1 transaction to be reported: i. A person did a suspicious outward remittance to a foreign entity This transaction contains 1 person and 1 entity to be reported: i. Person who did the outward remittance ii. Entity which received the funds from outward remittance Prepare PAE and transaction details tables as below (since this is a person to entity transaction, person details and entity details tables are required):
[Limited Sharing] Submitting STR Report Demonstration 2 (P to E) Person Details Person 1* Entity Details Entity 1 Suspect? Yes Suspect? Yes First Name Kamal Name Star Fashion (Pvt) Ltd Last Name SILVA Inc. Number Birthdate 01/06/1970 Inc. Legal Form NIC Number 700123456V Inc. Country Nationality Sri Lanka Inc. Date Residence Sri Lanka Business Occupation Tailor Address Type *If Person 1 is a not my client , only First Name and Last Name are mandatory. But always provide all details where possible Address Type Personal Address Address 22, Janatha Mawatha, Borella Address District Address Country Address District Colombo Director(s) Address Country Sri Lanka
[Limited Sharing]Submitting STR Report Demonstration 2 (P to E) Transaction Details Transaction 1 Transaction Number TXN003 Transaction Mode Other Trnx Mode Comment Outward remittance to Sweden Local Amount (LKR) 2,000,000 Date 18/08/2023 Transaction Location Colombo Fort Nature of Transaction Outward remittance to Sweden Bi Party? Yes From Party / Multi Party Person - 700123456V From Funds Code Cash From Forex Details To Funds Code Cash To Forex Details 67,170 Swedish Krona @ 29.48 LKR exchange rate To Party Entity - Star Fashion (Pvt) Ltd Comments Sent the amount to foreign entity and informed it was for a business payment
[Limited Sharing] Submitting PAE Report Demonstration 2 (P to E) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Person 1 (Relationship: My Client) - 700123456V Entity 1 (Relationship: Not My Client) Star Fashion (Pvt) Ltd
[Limited Sharing] Submitting STR Report Demonstration 3 (P to A) Scenario a person made a suspicious cash deposit to his account which is jointly owned with another person (his wife) Following is the breakdown of this scenario for STR reporting: There is 1 transaction to be reported: i. A person did a suspicious cash deposit to his account which is jointly owned with another person (his wife) This transaction contains 2 person and 1 account to be reported: i. 2 account owners (one of them is the depositor) ii. Account which received the deposit Prepare PAE and transaction details tables as below (since this is a person to account transaction, person details and account details tables are required):
[Limited Sharing] Submitting STR Report Demonstration 3 (P to A) Person Details Person 1 Person 2 Suspect? Yes No First Name Ruwan Nethmi Malsha Last Name FERNANDO FERNANDO Birthdate 25/03/1995 31/08/1999 NIC Number 950123456V 990123456V Nationality Sri Lanka Sri Lanka Residence Sri Lanka Sri Lanka Occupation Engineer Doctor Address Type Personal Personal Address No. 33, Barnes Place, Colombo 07 No. 33, Barnes Place, Colombo 07 Address District Colombo Colombo Address Country Sri Lanka Sri Lanka
[Limited Sharing]Submitting STR Report Demonstration 3 (P to A) Account Details Account 1 Suspect? Yes Account Number TSTACC001 Acc Holding Institution Test Bank Limited SWIFT/LankaCLear/LankaFIN Code TSTBLKXX Branch Fort Type Savings Status Active Currency LKR Opening Purpose Salary receipts Opened Date 01/01/2020 Closed Date Balance 5,000,000 Date Balance 18/08/2023 [Account Own] Entity [Account Own] Signatory(ies) Person - 950123456V (reuse), Person - 990123456V
[Limited Sharing]Submitting STR Report Demonstration 3 (P to A) Transaction Details Transaction 1 Transaction Number TXN004 Transaction Mode Branch Trnx Mode Comment Local Amount (LKR) 1,000,000 Date 18/08/2023 Transaction Location Colombo Fort Nature of Transaction OTC cash deposit Bi Party? Yes From Party / Multi Party Person - 950123456V From Funds Code Cash From Forex Details To Funds Code Electronic To Forex Details To Party Account - TSTACC001 Comments Customer was very nervous and was in a big hurry to complete the deposit. Also, this is the first cash deposit to this account
[Limited Sharing] Submitting PAE Report Demonstration 3 (P to A) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Person 1 (Relationship: My Client) - 950123456V Account 1 (Relationship: My Client) TSTACC001
[Limited Sharing] Submitting STR Report Demonstration 4 (E to E) Scenario a person representing an entity received a suspicious inward remittance from a foreign entity Following is the breakdown of this scenario for STR reporting: There is 1 transaction to be reported: i. A person representing an entity received a suspicious inward remittance from a foreign entity This transaction contains 2 entities to be reported: i. Foreign entity which sent the remittance and local entity which received it There is a separate element named Conductor to report details of the person who received the amount (optional, but preferred), but it requires usage of not my client elements in the report. Prepare PAE and transaction details tables as below (since this is an entity to entity transaction, entity details [and optionally conductor details] tables are required):
[Limited Sharing] Submitting STR Report Demonstration 4 (E to E) Entity Details Entity 1 Entity 2 Suspect? Yes Yes Name Yokoshuma Automobiles Limited Fresh Sea Food (Pvt) Ltd Inc. Number Inc. Legal Form Inc. Country Japan Sri Lanka Inc. Date Business Address Type Address Address District Address Country Director(s)
[Limited Sharing] Submitting STR Report Demonstration 4 (E to E) Person Details Person 1* Suspect? Yes First Name Jayantha Last Name BANDARA Birthdate 10/04/1988 NIC Number 960123456V Nationality Sri Lanka Residence Sri Lanka Occupation Clerk Address Type Personal Address No. 33, Barnes Place, Colombo 07 Address District Colombo Address Country Sri Lanka *Conductor details optional but preferred
[Limited Sharing]Submitting STR Report Demonstration 4 (E to E) Transaction Details Transaction 1 Transaction Number TXN005 Transaction Mode Other Trnx Mode Comment Inward remittance from Japan Local Amount (LKR) 10,000,000 Date 18/08/2023 Transaction Location Colombo Fort Nature of Transaction Inward remittance from Japan Bi Party? Yes From Party / Multi Party Entity - Yokoshuma Automobiles Limited From Funds Code Cash From Forex Details 4,502,470 Japanese Yen @ 2.20 LKR exchange rate To Funds Code Cash To Forex Details To Party Entity - Fresh Sea Food (Pvt) Ltd Comments Received the amount from foreign entity and informed it was for a business settlement. Conductor details are also given in the report
[Limited Sharing] Submitting PAE Report Demonstration 4 (E to E) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Entity 1 (Relationship: Not My Client) Yokoshuma Automobiles Limited Entity 2 (Relationship: Not My Client) Fresh Sea Food (Pvt) Ltd Person 1 [Conductor] (Relationship: Not My Client) - 960123456V
[Limited Sharing] Submitting STR Report Demonstration 5 (E to A) Scenario a person representing an entity made 2 suspicious cash deposits to the entity account (where he is a director) and his personal account Following is the breakdown of this scenario for STR reporting: There are 2 transactions to be reported: i. A person representing an entity made a cash deposit to the entity account ii. Same person made another cash deposit to his own account These transactions contain 1 entity, 2 accounts, and 2 persons (1 person in 3 roles) to be reported: i. Entity which owned the cash deposited account ii. Entity account and person account which received cash deposits iii. Peron who deposited cash (as conductor, entity director, and account owner) and another director There is a separate element named Conductor to report details of the person who made the deposit (optional, but preferred), but it requires usage of not my client elements in the report. Prepare PAE and transaction details tables as below (since this is an entity to account transaction, entity details, account details and person details tables are required):
[Limited Sharing] Submitting STR Report Demonstration 5 (E to A) Person Details Person 1* Person 2** Suspect? Yes No First Name Jayantha Gayan Kithsiri Last Name BANDARA RAMANAYAKA Birthdate 10/04/1988 NIC Number 880123456V 790123456V Nationality Sri Lanka Sri Lanka Residence Sri Lanka Sri Lanka Occupation Clerk Address Type Personal Address No. 33, Barnes Place, Colombo 07 Address District Colombo Address Country Sri Lanka *can be reported as a conductor too optional but preferred ** entity director
[Limited Sharing] Submitting STR Report Demonstration 5 (E to A) Entity Details Entity 1 Suspect? Yes Name Nimal Ironworks (Pvt) Ltd Inc. Number PV001 Inc. Legal Form Private Limited Company Inc. Country Sri Lanka Inc. Date 25/11/2015 Business Iron items manufacturing Address Type Business Address 44, Lake Road, Kandy Address District Kandy Address Country Sri Lanka Director(s) 880123456V, 790123456V
[Limited Sharing]Submitting STR Report Demonstration 5 (E to A) Account Details Account 1 Account 2 Suspect? Yes Yes Account Number TSTACC002 TSTACC003 Acc Holding Institution Test Bank Limited Test Bank Limited SWIFT/LankaCLear/LankaFIN Code TSTBLKXX TSTBLKXX Branch Kandy Galle Type Current Savings Status Active Active Currency LKR LKR Opening Purpose Business proceeds Personal savings Opened Date 30/11/2015 20/06/2008 Closed Date Balance 25,000,000 1,250,000 Date Balance 18/08/2023 18/08/2023 [Account Own] Entity PV001 [Account Own] Signatory(ies) 880123456V
[Limited Sharing]Submitting STR Report Demonstration 5 (E to A) Transaction Details Transaction 1 Transaction 2 Transaction Number TXN006 TXN007 Transaction Mode Branch Branch Trnx Mode Comment Local Amount (LKR) 2,000,000 500,000 Date 18/08/2023 18/08/2023 Transaction Location Colombo Fort Colombo Fort Nature of Transaction OTC cash deposit OTC cash deposit Bi Party? Yes Yes From Party / Multi Party Entity PV001 Person - 880123456V From Funds Code Cash Cash From Forex Details To Funds Code Electronic Electronic To Forex Details To Party Account TSTACC002 Account TSTACC003 Comments Typically, a clerk comes to deposit but this time the director himself came and made the deposit in a suspicious manner. Made at the same time of the deposit for the entity account. Does not align with the customer profile
[Limited Sharing] Submitting PAE Report Demonstration 5 (E to A) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Person 1 (Relationship: My Client) 880123456V Entity 1 (Relationship: My Client) PV001 Account 1 (Relationship: My Client) - TSTACC002 Account 2 (Relationship: My Client) - TSTACC003
[Limited Sharing] Submitting STR Report Demonstration 6 (1) (A to A) Scenario 1 a suspicious fund transfer was made from one personal account (my client) to another personal account (my client) Following is the breakdown of this scenario for STR reporting: There is 1 transaction to be reported: i. A suspicious fund transfer was made from one personal account to another personal account This transaction contains 2 accounts and 2 persons to be reported: i. Account which made the fund transfer and account which received funds ii. Persons who own the accounts Prepare PAE and transaction details tables as below (since this is an account to account transaction, account details and person details tables are required):
[Limited Sharing] Submitting STR Report Demonstration 6 (1) (A to A) Person Details Person 1 Person 2 Suspect? Yes Yes First Name Nishantha Hansi Jayamali Last Name JAYAKODI RATHNAWEERA Birthdate 19/07/1984 21/01/1996 NIC Number 840123456V 960123456V Nationality Sri Lanka Sri Lanka Residence Sri Lanka Sri Lanka Occupation Chef Textiles Business Address Type Personal Personal Address No. 77, Temple Road, Akuressa No. 55, Flower Road, Gampaha Address District Matara Gampaha Address Country Sri Lanka Sri Lanka
[Limited Sharing] Submitting STR Report Submitting STR Report Demonstration 6 (1) (A to A) Demonstration 6 (1) (A to A) Account Details Account 1 Account 2 Suspect? Yes Yes Account Number TSTACC004 TSTACC005 Acc Holding Institution Test Bank Limited Test Bank Limited SWIFT/LankaCLear/LankaFIN Code TSTBLKXX TSTBLKXX Branch Matara Main Gampaha Super Type Savings Savings Status Active Active Currency LKR LKR Opening Purpose Business proceeds Personal savings Opened Date 20/08/2013 20/08/2013 Closed Date Balance 25,000 1,500,000 Date Balance 18/08/2023 18/08/2023 [Account Own] Entity [Account Own] Signatory(ies) 840123456V 960123456V
Submitting STR Report Submitting STR Report Demonstration 6 (1) (A to A) Demonstration 6 (1) (A to A) [Limited Sharing] Transaction Details Transaction 1 Transaction Number TXN008 Transaction Mode Internet Banking Trnx Mode Comment Local Amount (LKR) 250,000 Date 18/08/2023 Transaction Location Internet Banking Nature of Transaction Fund transfer using internet banking Bi Party? Yes From Party / Multi Party Account - TSTACC004 From Funds Code Electronic From Forex Details To Funds Code Electronic To Forex Details To Party Account - TSTACC005 Comments One of many fund transfers made from this account to other accounts which are not matching with the customer s updated profile
[Limited Sharing] Submitting PAE Report Demonstration 6 (1) (A to A) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Person 1 (Relationship: My Client) 840123456V Person 2 (Relationship: My Client) 960123456V Account 1 (Relationship: My Client) - TSTACC004 Account 2 (Relationship: My Client) - TSTACC005
[Limited Sharing] Submitting STR Report Demonstration 6 (2) (A to A) Scenario 2 a suspicious fund transfer was received from another bank account (not my client) to a personal account (my client) Following is the breakdown of this scenario for STR reporting: There is 1 transaction to be reported: i. A suspicious fund transfer was received from another bank account (not my client) to a personal account (my client) This transaction contains 2 accounts and 1 person to be reported: i. Account which received the fund transfer (my client) and account which sent funds (not my client) ii. Persons who own my client account Prepare PAE and transaction details tables as below (since this is an account to account transaction, account details and person details tables are required):
[Limited Sharing] Submitting STR Report Demonstration 6 (2) (A to A) Person Details Person 1 Suspect? Yes Title Rev. First Name Laagal Lande Last Name DEWADATHTHA THERO Birthdate 13/06/1973 NIC Number 730123456V Nationality Sri Lanka Residence Sri Lanka Occupation Priest Address Type Personal Address No. 77, Sadaham Road, Anuradhapura Address District Anuradhapura Address Country Sri Lanka
[Limited Sharing] Submitting STR Report Submitting STR Report Demonstration 6 (2) (A to A) Demonstration 6 (2) (A to A) Account Details Account 1 Account 2 Suspect? Yes Yes Account Number TSTACC006 TSTACC007 Acc Holding Institution Test Bank Limited Bank of Ceylon SWIFT/LankaCLear/LankaFIN Code TSTBLKXX BCEYLKLXXXX Branch Anuradhapura 007 Type Savings Status Active Currency LKR Opening Purpose Personal Savings Opened Date 03/12/2011 Closed Date Balance 25,000,000 Date Balance 18/08/2023 18/08/2023 [Account Own] Entity [Account Own] Signatory(ies) 730123456V
Submitting STR Report Submitting STR Report Demonstration 6 (2) (A to A) Demonstration 6 (2) (A to A) [Limited Sharing] Transaction Details Transaction 1 Transaction Number TXN009 Transaction Mode Internet Banking Trnx Mode Comment Local Amount (LKR) 1,750,000 Date 18/08/2023 Transaction Location Internet Banking Nature of Transaction Fund transfer using internet banking Bi Party? Yes From Party / Multi Party Account - TSTACC007 From Funds Code Electronic From Forex Details To Funds Code Electronic To Forex Details To Party Account - TSTACC006 Comments Unusually large fund transfer received to the account 2 days after a golden statue was stolen from the temple (as per news)
[Limited Sharing] Submitting PAE Report Demonstration 6 (2) (A to A) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Person 1 (Relationship: My Client) 730123456V Account 1 (Relationship: My Client) - TSTACC006 Account 2 (Relationship: Not My Client) - TSTACC007
[Limited Sharing] Submitting STR Report Demonstration 6 (3) (A to A) Scenario 3 2 suspicious fund transfers were observed as below: Transaction 1 Account 1 Account 2 Entity 1 Entity 2 Director 1 Director 3 Director 2 Transaction 2 Account 4 Account 3
[Limited Sharing] Submitting STR Report Demonstration 6 (3) (A to A) Following is the breakdown of this scenario for STR reporting: There are 2 transactions to be reported: i. A suspicious fund transfer was made from one entity account to another entity account ii. A suspicious fund transfer was made from one personal account to another personal account These transactions contain 4 accounts, 2 entities, and 3 persons to be reported: i. 2 entity accounts and 2 personal accounts ii. 2 entities which own the entity accounts iii. 3 persons which are directors of 2 entities (1 is common) and 2 of them are also owners of the personal accounts Prepare PAE and transaction details tables as below (since these are account to account transactions (entity and personal), account details, entity details, and person details tables are required):
[Limited Sharing] Submitting STR Report Demonstration 6 (3) (A to A) Person Details Person 1 Person 2 Person 3 Suspect? Yes Yes No First Name Mohan Nimal Chinthaka Last Name RAJASOORIYA RAJASOORIYA WILLIAM Birthdate 01/01/1969 01/02/1999 01/04/2005 NIC Number 690123456V 990123456V 200512345678 Nationality Sri Lanka Sri Lanka Sri Lanka Residence Sri Lanka Sri Lanka Sri Lanka Occupation Director Director Director Address Type Personal Personal Personal Address No. 69, Raja Mawatha, Tangalle No. 35, Lotus Road, Hambantota No. 57, Spencer Road, Colombo 06 Address District Tangalle Hambantota Colombo Address Country Sri Lanka Sri Lanka Sri Lanka
[Limited Sharing] Submitting STR Report Demonstration 6 (3) (A to A) Entity Details Entity 1 Entity 2 Suspect? Yes Yes Name Ceylon Nationality Front (Pvt) Ltd Lanka Religious Business Academy (Pvt) Ltd Inc. Number CNF001 LRBA001 Inc. Legal Form Private Limited Company Private Limited Company Inc. Country Sri Lanka Sri Lanka Inc. Date 20/05/2009 20/05/2009 Business Advertising (promote nationality) Ideology Business Address Type Business Business Address 609, Independence Square, Colombo 05 77, Dalada Road, Kandy Address District Colombo Kandy Address Country Sri Lanka Sri Lanka Director(s) Person - 690123456V Person - 200512345678 Person - 990123456V
Submitting STR Report Demonstration 6 (3) (A to A) [Limited Sharing] Account Details Account 1 Account 2 Account 3 Account 4 Suspect? Yes Yes Yes Yes Account Number TSTACC008 TSTACC009 TSTACC010 TSTACC011 Acc Holding Institution Test Bank Limited Test Bank Limited Test Bank Limited Test Bank Limited SWIFT/LankaCLear/LankaFIN Code TSTBLKXX TSTBLKXX TSTBLKXX TSTBLKXX Branch Head Office Head Office Head Office Head Office Type Current Current Savings Savings Status Active Active Active Active Currency LKR LKR LKR LKR Opening Purpose Business proceeds Business proceeds Personal expenses Personal expenses Opened Date 20/05/2009 20/05/2009 20/05/2009 20/05/2009 Closed Date Balance 25,000 10,000 50,000,000,000 5,000,000,000 Date Balance 18/08/2023 18/08/2023 18/08/2023 18/08/2023 [Account Own] Entity CNF001 LRBA001 [Account Own] Signatory(ies) Person - 690123456V Person - 990123456V
Submitting STR Report Submitting STR Report Demonstration 6 (3) (A to A) Demonstration 6 (3) (A to A) [Limited Sharing] Transaction Details Transaction 1 Transaction 2 Transaction Number TXN010 TXN011 Transaction Mode Internet Banking Internet Banking Trnx Mode Comment Local Amount (LKR) 1,000,000,000 1,000,000,000 Date 18/08/2023 18/08/2023 Transaction Location Internet Banking Internet Banking Nature of Transaction Fund transfer using internet banking Fund transfer using internet banking Bi Party? Yes Yes From Party / Multi Party Account - TSTACC008 Account - TSTACC010 From Funds Code Electronic Electronic From Forex Details To Party Account - TSTACC009 Account - TSTACC011 To Funds Code Electronic Electronic To Forex Details Comments One of many transactions that occur between these 2 accounts. Lots of inward transactions to TSTACC008 which gets transferred to TSTACC009 One of few transactions that happens occasionally between these 2 accounts. TSTACC010 receives many cash deposits which are transferred to TSTACC011
[Limited Sharing] Submitting PAE Report Demonstration 6 (3) (A to A) Include the STR reference number (in the format STR-N: XXXXX-X- X) in the field FIU Reference Following are the PAEs to be reported in the PAE report: Person 1 (Relationship: My Client) 690123456V Person 2 (Relationship: My Client) 990123456V Entity 1 (Relationship: My Client) CNF001 Entity 2 (Relationship: My Client) 730123456V Account 1 (Relationship: My Client) - TSTACC006 Account 2 (Relationship: Not My Client) - TSTACC007 Account 3 (Relationship: My Client) - TSTACC006 Account 4 (Relationship: My Client) - TSTACC007
