Communication on Reporting: Monitoring Quality, Deletion of Draft Reports after 14 days, and Automatic Rejection Rules
3rd February 2021
Collecting Information on Quality of suspicious reports submitted
The FIAU started collecting information about the main reasons for rejection of suspicious reports submitted by reporting entities from 1 January 2021, in order to assess the quality of reporting.
This will assist the Unit in analysing the main reasons for the report rejection, such as:
- Whether the report was rejected by one of the automatic rejections rules;
- Choosing the wrong type of report (SAR/STR etc.);
- XML schema issues: fields are not aligned as needed, incorrect information included, etc.
- Documentation is lacking or is insufficient, incomplete or incorrect;
- Transactions Data is lacking or is incorrect or insufficient;
- Any other details of the report are missing, are incorrect, or not coherent.
Furthermore, collecting and analysing such information will enable the Unit to issue guidance to cater for the difficulties that the reporting entities are encountering with their submissions.
Data clean-up: Deletion of Draft Suspicious Reports after 14 calendar days from initiation
We would also like to remind the subject persons that the reporting obligation listed under section 5.5 of the Implementing Procedures part I specifies that “any disclosures should be made to the FIAU promptly, meaning that a suspicious transaction report should be submitted on the same day when knowledge or suspicion of ML/FT is considered to subsist by the MLRO”.
As of 1st March 2021, the FIAU will introduce a system by which draft suspicious reports – new drafts or drafts editable after rejection – will be deleted after 2 weeks (14 calendar days) from initiation.
Therefore, kindly ensure that any draft reports with initiation date before 12 February 2021 are finalised by this date, that they include all needed details of the suspicious activity/transaction, any supporting documentation, business and risk profile information etc. and that the reports are submitted to the FIAU by latest 26 February 2021.
As an example, a report submitted on the 18 of January 2021 and rejected on 20 January 2021, will be editable with initiation date still 18 of January 2021. If such report is not corrected and/or completed and re-submitted until 26 February 2021, the draft report will be deleted on 1st of March 2021.
After this date, any draft will be deleted from goAML after 14 days from initiation and the reporting persons will have to re-start the submission process.
Rejection Rule – Closed date should be included when an account is marked as closed
The FIAU added a new rejection rule as part of its report validation process.
This rejection rule ensures that when involved accounts in the schema are marked as being closed in their account status (“status_code”) the date when the account was closed would be required.
A correct example of how closed accounts should be reported in XML is as follows: