Financial Crime World

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Financial Regulators Unveil Comprehensive Guide to Reporting Suspicious Activities

In an effort to combat money laundering and terrorist financing, financial institutions and other entities are now required to report suspicious activities in a structured manner. A new guide has been released by the German Anti-Money Laundering Act (GwG) outlining the various reasons that may lead to the filing of a Suspicious Activity Report (SAR).

What is a Suspicious Activity Report (SAR)?

The SAR is designed to facilitate the documentation and reporting process to relevant authorities, such as the Financial Intelligence Unit (FIU). The form is comprehensive and includes fields marked with an asterisk (*), indicating required information. This ensures that suspicious activities are reported in a standardized and efficient manner.

Reasons for Filing a Suspicious Activity Report (SAR)

The document “Reasons for a Suspicious Activity Report (SAR)” outlines various reasons that may lead to the filing of an SAR. These reasons are categorized into different sections, each with specific codes and descriptions.

  • Legal Reasons according to Section 43 (1) GwG: This section covers money laundering and terrorist financing, including transactions related to these activities, business relationships, and brokerage businesses.
  • Determined Facts: This section focuses on customer-related peculiarities such as:
    • Politically exposed persons
    • List hits in sanctions lists
    • Knowledge from criminal investigations against customers
    • Transaction-related peculiarities like:
      • Economically implausible transactions
      • Unknown sources of funds
      • Use of anonymous payment procedures
      • Smurfing (splitting and merging amounts below threshold values)
  • Business Area: This section details abnormalities related to different types of transactions and financial activities, such as:
    • Credit
    • Securities
    • Insurance
    • Leasing
    • Foreign trade
    • Currency exchange
    • Prepaid cards
    • Credit cards
    • E-money
    • Cryptocurrencies
  • Predicate Offenses of Money Laundering: This section describes various predicate offenses that can lead to money laundering, including:
    • Corruption crimes in government offices
    • Fraud
    • Tax crimes
    • Benefits fraud
    • Terrorist financing
    • State security embargo violations
    • Other unspecified crimes

What is goAML?

The goAML application is a critical tool for Financial Intelligence Units (FIUs) in their efforts to combat money laundering and terrorist financing. Developed by the United Nations Office on Drugs and Crime (UNODC), goAML provides a platform to receive, process, and analyze reports and information related to suspicious financial activities.

Key Features of goAML

  • Purpose: To address the global challenges of money laundering and terrorist financing.
  • Functionality: Provides a critical tool for FIUs by receiving, processing, and analyzing reports and information related to suspicious financial activities.
  • Role in AML/CTF Efforts: Helps FIUs gather and analyze data that forms the basis for investigating money laundering, terrorist financing, and other serious criminal activities.

Global Adoption

As of now, goAML is utilized by over 60 member states, with many more countries showing interest in adopting this tool. The application enhances the ability of FIUs to perform their duties more efficiently and effectively, streamlining the process of data collection and analysis to aid in the timely detection and prevention of financial crimes.

Access

The goAML application can be accessed at https://goaml.fiu.bund.de/Home.

Sources:

  • German Anti-Money Laundering Act (Geldwäschegesetz – GwG)
  • BaFin-Interpretation and Application Guidance on the German Money Laundering Act
  • Form-Management-System of the Federal Finance Administration
  • FIU Information about the goAML software
  • UNODC goAML Web

Downloads:

  • Suspicious Activity Report (SAR) without Transaction
  • Suspicious Activity Report (SAR) with Transaction
  • Reasons for a Suspicious Activity Report (SAR)

By reporting suspicious activities in a structured and comprehensive manner, financial institutions can play a crucial role in preventing financial crimes and maintaining the integrity of the global financial system.