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Location: Central Bank of Bahrain Volume 1—Conventional Banks > Part A > Business Standards > FC Financial Crime > FC-5 Suspicious Transaction Reporting
  • FC-5 Suspicious Transaction Reporting

    • FC-5.1 Internal Reporting

      • FC-5.1.1

        Conventional bank licenseesG must implement procedures to ensure that staff who handle customer business (or are managerially responsible for such staff) make a report promptly to the MLRO if they know or suspect that a customer (or a person on whose behalf a customer may be acting) is engaged in money laundering or terrorism financing, or if the transaction or the customer's conduct otherwise appears unusual or suspicious. These procedures must include arrangements for disciplining any member of staff who fails, without reasonable excuse, to make such a report.

        October 07

      • FC-5.1.2

        Where conventional bank licenseesG ' internal processes provide for staff to consult with their line managers before sending a report to the MLRO, such processes must not be used to prevent reports reaching the MLRO, where staff have stated that they have knowledge or suspicion that a transaction may involve money laundering or terrorist financing.

        October 07

    • FC-5.2 External Reporting

      • FC-5.2.1

        Conventional bank licenseesG must take reasonable steps to ensure that all reports made under Section FC-5.1 are considered by the MLRO (or his duly authorised delegate). Having considered the report and any other relevant information the MLRO (or his duly authorised delegate), if he still suspects that a person has been engaged in money laundering or terrorism financing, or the activity concerned is otherwise still regarded as suspicious, must report the fact promptly to the relevant authoritiesG . Where no report is made, the MLRO must document the reasons why.

        October 07

      • FC-5.2.2

        To take reasonable steps, as required under Paragraph FC-5.2.1, conventional bank licenseesG must:

        (a) Require the MLRO to consider reports made under Section FC-5.1.1 in the light of all relevant information accessible to or reasonably obtainable by the MLRO;
        (b) Permit the MLRO to have access to any information, including know your customer information, in the conventional bank licenseeG 's possession which could be relevant; and
        (c) Ensure that where the MLRO, or his duly authorised delegate, suspects that a person has been engaged in money laundering or terrorist financing, a report is made by the MLRO which is not subject to the consent or approval of any other person.
        October 07

      • FC-5.2.3

        Reports to the relevant authoritiesG made under Paragraph FC-5.2.1 must be sent to the Financial Intelligence Unit at the Ministry of Interior and the CBB's Compliance Directorate using the Suspicious Transaction Report Online System (Online STR system). STRs in paper format will not be accepted.

        Amended: July 2016
        Amended: October 2014
        October 07

      • FC-5.2.4

        Conventional bank licenseesG must report all suspicious transactions or attempted transactions. This reporting requirement applies regardless of whether the transaction involves tax matters.

        October 07

      • FC-5.2.5

        Conventional bank licenseesG must retain all relevant details of STRs submitted to the relevant authoritiesG for at least five years.

        Amended: October 2014
        October 07

      • FC-5.2.6

        In accordance with the AML Law, conventional bank licenseesG , their DirectorG s, officers and employees:

        (a) Must not warn or inform ('tipping off') their customers, the beneficial owner or other subjects of the STR when information relating to them is being reported to the relevant authoritiesG ; and
        (b) In cases where conventional bank licenseesG form a suspicion that transactions relate to money laundering or terrorist financing, they must take into account the risk of tipping-off when performing the CDD process. If the conventional bank licenseeG reasonably believes that performing the CDD process will tip-off the customer or potential customer, it may choose not to pursue that process, and must file an STR.
        Amended: January 2018
        October 07

    • FC-5.3 Contacting the Relevant Authorities

      • FC-5.3.1

        Reports made by the MLRO or his duly authorised delegate under Section FC-5.2 must be sent electronically using the Suspicious Transaction Reporting Online System (Online STR system).

        Amended: October 2014
        October 07

      • FC-5.3.2

        The relevant authoritiesG are:

        Financial Intelligence Directorate (FID)
        General Directorate of Anti Corruption and Economic and Electronic Security
        Ministry of Interior
        P.O. Box 26698
        Manama, Kingdom of Bahrain
        Telephone: + 973 17 749397
        Fax: + 973 17 715502
        E-mail: bahrainfid@moipolice.bh

        Director of Compliance Directorate
        Central Bank of Bahrain
        P.O. Box 27
        Manama, Kingdom of Bahrain
        Telephone: 17 547107
        Fax: 17 535673
        E-mail: Compliance@cbb.gov.bh

        Added: October 2014

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