The Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 requires firms to report suspicious transactions based on the premise that a person ‘knows, suspects or has reasonable grounds to suspect, based on information obtained in the course of carrying on business as designated person’ that another person is involved in money laundering or terrorist financing. This is quite a low bar, as neither proof nor documentary evidence is required.
Suspicious Transaction Reports (STRs) are made internally within the accountancy firm to the Money Laundering Reporting Officer (MLRO) who is the only person designated by the legislation within the firm who may make an external report.
The external report is made the Garda Síochana online at GoAML and is copied to the Revenue Commissioners by post, even if it does not involve taxation.
More details on the reporting requirements are set out in our newly published AML Policies & Procedures Manual, which is available here.
It is fully updated for the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 which came into force on 26 November 2018. It retails at €150+VAT.
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