Financial Crime World

Suspicious Activity Reporting in Greenland

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Overview

In Greenland, financial institutions and businesses are required to report suspicious activities to the relevant authorities as part of efforts to combat money laundering and other illicit financial activities.

What is a Suspicious Activity Report?


A Suspicious Activity Report (SAR) is a document that must be filed with the Financial Crimes Enforcement Network (FinCEN) when an organization detects suspicious activity that may indicate financial crime. This can include unusually large cash transactions, frequent wire transfers, and other activities that seem to be designed to evade detection.

Which Organizations Are Required to File SARs?


The following organizations are required to file SARs:

  • Banks and credit unions: Must report suspicious activities when they detect transactions or patterns of transactions that could signal illegal activity.
  • Money service businesses (MSBs): Include check cashing services, currency exchange services, and money transmitter services.
  • Mutual funds, securities brokers and dealers: Must file a SAR if they detect suspicious transactions in the accounts of their customers.
  • Casinos: Must report suspicious activities when they detect transactions or patterns of transactions that could signal illegal activity.
  • Insurance companies: Must file a SAR if they detect suspicious transactions in the accounts of their policyholders.

Suspicious Activity Reporting Requirements


Organizations must report suspicious activities when they detect:

  • Transactions involving funds derived from illegal activities
  • Transactions designed to evade reporting requirements
  • Transactions with no apparent business or lawful purpose

Examples of Suspicious Activities


Some examples of suspicious activities that may warrant a SAR include:

  • Large cash deposits or withdrawals: Amounts significantly larger than usual.
  • Frequent wire transfers: Transfers made in quick succession, potentially indicating money laundering.
  • Rapid movement of funds between bank accounts or between different types of accounts within the same institution: May indicate an attempt to disguise the source or destination of the funds.
  • Mismatched records: Inconsistencies between customer information and transaction data.
  • Overcomplicated transactions: Transactions with multiple parties, complex payment structures, or other features that may be used to conceal the true nature of the transaction.

How to Submit a Suspicious Activity Report


The process of submitting a SAR involves several steps:

  1. Detection: The organization must detect suspicious activity.
  2. Documentation: The organization must gather all relevant information about the suspicious activity, including the date and time of the activity, the parties involved, the nature and amount of the transactions, and why the activity was deemed suspicious.
  3. Submission: After the information has been compiled, the institution must submit the report to FinCEN using their BSA E-Filing System.

Manual vs. Automatic Suspicious Activity Reporting


Organizations have two options for submitting SARs: manual or automatic reporting.

  • Manual filing: Involves each report being completed by hand, which is time-consuming and outdated.
  • Automatic regulatory reporting: Relies on software solutions like Alessa to streamline the process, reducing time spent on reports and increasing accuracy.

Sources


For more information on suspicious activity reporting in Greenland, refer to:

  • Electronic Filing Instructions