Suspicious Activity Reporting & Beneficial Ownership System Guidelines
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Text
Suspicious Activity or Transaction Reporting
&
Beneficial Ownership Secure Search System
Presented by:
Dwyane A. Thomas
Ag. Deputy Director
Financial Investigation Agency
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AGENDA
Suspicious
T
ransaction
or
Activity
R
eport
Do’s and Don’ts when submitting SARs/STRs
Reports received from various sectors
Reactive vs. Proactive reporting
Reporting a Client subject to a Sanction
Beneficial Ownership Secure Search system (BOSSs)
Security of information
Level of population
2017 – 2019 statistics (Expectation vs Reality)
Integrity of information
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Do’s and
Don’ts when
submitting a
STR/SAR
Submit a
SAR
for
suspicious
behavior,
Provide a detailed clear trail
Provide all supporting documentation
(source of funds, linked accounts, due diligence details etc.)
Report within a reasonable timeframe
Provide
a soft
copy SAR
form
Avoid “
T
ipping Off”
Audit Trail all supplemental SAR information
Do maintain
your SARs
as
per the prescribed
r
ecord
keeping
r
equirements
Provide
your conta
c
t
details to the FIA
Do’s
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Do’s and
Don’ts when
submitting a
STR/SAR
Don’ts
Do
not
termin
a
te
the relationship intentionally p
r
ior
or
post
raising the SAR unless there
is
a logi
c
al
and/or
unavoidable
reason behind such action. Please wait for
an offi
c
ial
response from
the FIA.
Do
not insert “ref
e
r
to
documents at
t
ached”
under
“Source of
Suspicion.”
A brief
explanation in the
space provided
is
required and
ALWAYS
identify the
suspici
o
n clearly
and concisel
y
.
C
o
r
p
o
r
a
t
e
S
e
r
v
i
c
e
P
r
o
v
i
d
e
r
s
What we’ve seen
Reactive reporting
Late reporting
Lack of supporting information
Unidentified breaches
Unaware of clients activities
Proactive reporting
Timely r
eporting (time sensitive)
Complete
information
C KYC / Ongoing monitoring clients
Use of
Internal reporting register
What we want to see
B
a
n
k
i
n
g
S
e
c
t
o
r
Reactive reporting
Late reporting (6 month delays)
Lack of supporting information
Incomplete responses
Lack of dialogue with customers
Proactive reporting
Time sensitive reporting
Complete i
nformation (CDD, etc.)
Better use of internal processes
Communication with customers
What we want to see
What we’ve seen
S
h
i
f
t
i
n
g
f
r
o
m
R
e
a
c
t
i
v
e
t
o
P
r
o
a
c
t
i
v
e
R
e
p
o
r
t
i
n
g
S
talled investigation
Loss of data and evidence
Investigation in other jurisdiction
Reputational risk
Possible collapse of financial centre
Reactive
Enhanced analysis/investigation
capabilities
Readily accessible data/evidence
Better chances of convictions
Less reputational risk
Enhanced client monitoring
Proactive
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Obligation to Financial Investigation Agency
In general, a regulated person shall not carry on business with Individuals, business entities,
organizations, jurisdictions, territories or states subject to United Nations’ or any other sanctions
applicable in the jurisdiction as it is an offence. If the regulated entity receives instructions or a business
request from a person or persons designated on sanction list, the compliance officer/MLRO of the
regulated entity shall immediately submit Suspicious Activity Report to the Financial Investigation Agency.
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Obligation to Governor’s Office (Licensing)
A regulated entity must inform the Governor as soon as practicable if it knows or suspects that a customer is from a
Sanctioned Nation.
When reporting, the regulated entity must state:
(a) the information or other matter on which the knowledge or suspicion is based,
(b) any information it holds about the customer by which the customer can be identified, and
(c) the nature and amount or quantity of any funds or economic resources held by the relevant regulated entity for
the customer
The Governor may, grant a licence authorising an activity that would otherwise be prohibited with a designated person
and likewise vary or revoke the said licence.
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Organi
s
at
io
ns
and
Bus
i
n
e
ss
e
s
a
r
e
ob
l
igat
e
d
t
o
make
S
A
R/
ST
R
.
A
s
s
o
on
as
an
Organi
s
at
io
n
or Busin
e
ss
‘
kn
ows’
or
‘
s
usp
e
cts’
or
has
rea
s
onable
grounds
t
o
s
u
spect
t
h
at
funds
a
r
e
th
e
proc
e
eds of
a
cr
i
minal
act
ivi
t
y
,
or
a
r
e
r
el
a
ted
t
o
t
e
rr
or
i
s
t
fin
a
ncing,
i
t
sh
o
uld
rep
o
rt
promptly
it
s
sus
p
ici
o
n to the
Financial
Inve
s
t
i
gat
i
on
Agenc
y
.
Y
our
MLRO
can
send
a Suspici
o
us
Acti
vi
ty
R
epo
r
t
to
the
FIA:
Electr
o
n
i
cally to
report
i
ngaut
h
o
r
i
ty@
b
v
i
fia.
o
rg
by
fax
to 28
4
-49
4
-1435
by couri
e
r
or hand delivered
to
the
Financial
Inves
t
ig
a
t
i
on
Agenc
y
,
2nd Floo
r
,
Ri
t
t
e
r
House,
W
ickham
’
s
Cay
II,
R
oad
T
own,
T
ortola
R
epor
t
i
ng
a
S
A
R/
STR
p
r
o
t
ects
y
o
u
and
yo
u
r
or
ganisat
i
on/bu
s
in
e
ss
from
t
he
r
i
s
k
of
launde
ri
ng
t
he proceeds
of
crime
or
being
used
as
a vehicle
for
terro
ri
sm
financing.
Report Suspicious Activities or Transactions
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Summary
It
i
s
important
that
the
Or
g
a
n
isation
and
Business
repo
r
t
Sus
p
ic
i
ous
T
r
a
nsactions
or
Suspicious
Activities.
K
ee
p
s
taff educated and info
r
me
d
o
f
their o
b
l
i
gations under the appl
i
cab
l
e
legislation
in order
to
lawful
l
y
operate within the
T
erritor
y
.
Implem
e
nt
y
o
ur
c
o
mplia
n
ce
p
o
l
i
cies
and
en
c
ourage
a
culture
o
f
c
ompliance
in
your
organisation.
•
Du
m
my
•
Tex
t
Beneficial Ownership Secure Search system
(BOSSs)
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Beneficial Ownership Secure Search system (BOSSs)
Other Facts:-
Population – Currently 95% as of 1 June 2019
Security of information – Highest level of encryption
Restricted searchability – No unauthorised searching
Integrity of information –
ALWAYS
verify information
Still one of a kind – Duplication will eventually happen
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THANK
YOU
ANY
QUE
S
TIONS?
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Text
Learn about the dos and don'ts of reporting suspicious activities and transactions, understanding beneficial ownership, and the importance of secure search systems. Discover insights on submitting reports, maintaining integrity, and transitioning from reactive to proactive reporting in various sectors like corporate services and banking.
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Presentation Transcript
Suspicious Activity or Transaction Reporting & Beneficial Ownership Secure Search System Dummy Text Presented by: Dwyane A. Thomas Ag. Deputy Director Financial Investigation Agency
AGENDA Suspicious T ransaction or Activity Report Do s and Don ts when submitting SARs/STRs Reports received from various sectors Reactive vs. Proactive reporting Reporting a Client subject to a Sanction Beneficial Ownership Secure Search system (BOSSs) Security of information Level of population 2017 2019 statistics (Expectation vs Reality) Dummy Text Integrity of information
Dos Do s and Don ts when submitting a STR/SAR Submit a SAR for suspicious behavior, Provide a detailed clear trail Provide all supporting documentation (source of funds, linked accounts, due diligence details etc.) Report within a reasonable timeframe Provide a soft copy SAR form Avoid Tipping Off Audit Trail all supplemental SAR information Do maintain your SARs as per the prescribed record keeping requirements Provide your contact details to the FIA Dummy Text
Donts Do s and Don ts when submitting a STR/SAR Do not terminate the relationship intentionally prior or post raising the SAR unless there is a logical and/or unavoidable reason behind such action. Please wait for an official response from the FIA. Do not insert refer to documents attached under Source ofSuspicion. A brief explanation in the space provided is required and ALWAYS identify the suspicion clearly and concisely . Dummy Text
Corporate Service Providers Corporate Service Providers What we ve seen What we want to see Proactive reporting Reactive reporting Timely reporting (time sensitive) Late reporting Complete information Lack of supporting information C KYC / Ongoing monitoring clients Unidentified breaches Use of Internal reporting register Unaware of clients activities
Banking Sector Banking Sector What we ve seen What we want to see Proactive reporting Reactive reporting Time sensitive reporting Late reporting (6 month delays) Complete information (CDD, etc.) Lack of supporting information Better use of internal processes Incomplete responses Communication with customers Lack of dialogue with customers
Shifting from Reactive to Proactive Reporting Shifting from Reactive to Proactive Reporting Reactive Proactive Stalled investigation Enhanced analysis/investigation capabilities Loss of data and evidence Readily accessible data/evidence Investigation in other jurisdiction Better chances of convictions Reputational risk Less reputational risk Possible collapse of financial centre Enhanced client monitoring
Obligation to Financial Investigation Agency In general, a regulated person shall not carry on business with Individuals, business entities, organizations, jurisdictions, territories or states subject to United Nations or any other sanctions applicable in the jurisdiction as it is an offence. If the regulated entity receives instructions or a business request from a person or persons designated on sanction list, the compliance officer/MLRO of the regulated entity shall immediately submit Suspicious Activity Report to the Financial Investigation Agency. Dummy Text
Obligation to Governors Office (Licensing) A regulated entity must inform the Governor as soon as practicable if it knows or suspects that a customer is from a Sanctioned Nation. When reporting, the regulated entity must state: (a) the information or other matter on which the knowledge or suspicion is based, (b) any information it holds about the customer by which the customer can be identified, and (c) the nature and amount or quantity of any funds or economic resources held by the relevant regulated entity for the customer The Governor may, grant a licence authorising an activity that would otherwise be prohibited with a designated person and likewise vary or revoke the said licence. Dummy Text
Report Suspicious Activities or Transactions Organisations and Businesses are obligated to make SAR/STR. As soon as an Organisation or Business knows or suspects or has reasonable grounds to suspect that funds are the proceeds of a criminal activity , or are related to terrorist financing, it should report promptly its suspicion to the Financial Investigation Agency . Y our MLRO can send a Suspicious Activity Report to the FIA: Electronically to reportingauthority@bvifia.org by fax to 284-494-1435 by courier or hand delivered to the Financial Investigation Agency , 2nd Floor , Ritter House, Wickham s Cay II, Road T own, T ortola Dummy Text Reporting a SAR/STR protects you and your organisation/business from the risk of laundering the proceeds of crime or being used as a vehicle for terrorism financing.
Summary It is important that the Organisation and Business report Suspicious T ransactions or Suspicious Activities. Keep staff educated and informed of their obligations under the applicable legislation in order to lawfully operate within the T erritory . Implement your compliance policies and encourage a culture of compliance in your organisation. Dummy Text
Beneficial Ownership Secure Search system (BOSSs) Du m my Tex t EXPECTATIONS ACTUALS 500000 160 450000 140 400000 142 120 350000 100 300000 250000 80 200000 60 150000 40 100000 39 38 20 50000 0 0 Annual Total Annual Total 2017 2018 2019 2017 2018 2019
Beneficial Ownership Secure Search system (BOSSs) Other Facts:- Population Currently 95% as of 1 June 2019 Security of information Highest level of encryption Restricted searchability No unauthorised searching Integrity of information ALWAYS verify information Still one of a kind Duplication will eventually happen Dummy Text
THANK YOU ANY QUESTIONS? Dummy Text
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