Bulk Reporting of Multiple Fraud-Related and Other Suspicious Transactions

January 20, 2016AMLC RESOLUTION NO. 05-16In the Memorandum dated 15 January 2016, the AMLC Secretariat (AMLCS) reported to the Council that: Bulk Reporting of Multiple Suspicious TransactionsResolution No. 43, Series of 2014, authorizes covered persons to submit fifty (50) or more suspicious transactions under one Suspicious Transaction Report STR. The authority was based on the impracticality of requiring covered persons to file STRs on each of these transactions. A case in point is when an investment scam breaks out where it is impractical for covered persons to report suspicious transactions on a daily basis.The guidelines in Resolution No. 43, Series of 2014, require that the reportable transactions should involve the same suspicious transaction indicator, and refer to the same accountholder and account number. The guidelines also provide that the transaction details shall be included as part of the narrative (not to exceed 4,000 characters) or can be extracted as an Excel file and submitted to the AMLC as an STR attachment.The guidelines, however, do not prescribe a standard reporting format. As a result, covered persons...