Key Learnings: Back2 Basics Training–Quality STR Review
The Association of Remittance Company Compliance Officer (ARCCO) in collaboration with the Anti-Money Laundering Council organized a Webinar on Back to Basics Training: Quality STR Filing on June 16, 2021.
The Webinar was hosted by Atty. Guada Vergel de Dios, President and Atty. Irene Victoria I. Torres, Chairman of ARCCO. Invited speakers on the subject matter were experts from the Anti-Money Laundering Council, headed by Ms. Marilyn S. Nunez, Bank Officer V at the Financial Intelligence and Analysis Group and Mr. Alvin A. Tollosa, CAMS and Data Collection Officer at the Detection and Prevention Department of the AMLC.
The Webinar aimed to re-educate the compliance officers and members of the covered entities in the significance of filing “effective and quality” Suspicious Transaction Report or STR. It was discussed that the core of any good anti-money laundering program is the STR which all covered persons must file when confronted with suspicious transactions. It was also emphasized that writing an effective and quality STR to meet regulatory requirements is an essential skill for any compliance officer.
“STRs enables better prioritization”
In this exclusive webinar, our expert speaker, Ms. Nunez highlighted that quality STR is one of the primary sources of intelligence for financial crime surveillance and investigation. Moreover, good quality STRs enables better prioritization, efficient allocation of resources to the AMLC. The speaker also presented the outcome of the 2021 STR Quality Review to the webinar participants. The STR study presented the trend analysis for the covered period 2017-2020, descriptive statistics on the date range of the STRs submitted, assessed the technical compliance and investigative values of the STRs, and identified the reporting gaps and challenges of covered persons, with the overall objective of providing guidance on how to further improve the quality of STRs.
The speaker lament that the study also cited certain data quality and system issues including over-usage of Suspicious Indicator (SI) 6 or transaction that are similar, analogous or identical to any of the foregoing for defensive reporting. She explained the use of SI6 could downplay the risk and prioritization of the STRs. Further, she explained that covered persons using SI6 with high-risk crimes as additional reason would circumvent the ARRG requirements of mandatory uploading of know-your-customer documents for PC1 or kidnapping for ransom, PC2 or drug trafficking and other related offenses, PC12 or hijacking, destructive arson, and murder, including those perpetrated by terrorists against non-combatant persons and similar targets, PC13 or terrorism and conspiracy to commit terrorism as well as PC14 or financing of terrorism.
A copy of the AMLC’s Suspicious Transaction Quality Review 2017 – 2020 Data Discovery is available at AMLC’s website http://www.amlc.gov.ph/.
Additionally, the AMLC speakers also informed the attendees of the new STR reporting format, and uploading KYC Documents and Electronic Statements of Accounts or ESOA.
