19:06 05.08.2011 - posted by
Armen, thanks a lot for your comment. In Russia we have to take into account STR indicators but the final decision on STR should be made by MLRO and we should not explain why we did not forward STRs to FIU on each transaction which corresponds to STR indicator.
10:58 04.08.2011 - posted by
Some good guidelines on STR regime (together with STR indicators), which I met in my practice are:
- Canadas FINTRAC Guideline 2 (http://www.fintrac.gc.ca/publications/guide/Guide2/2-eng.asp)
- UKs JMLSG (http://www.jmlsg.org.uk/industry-guidance/article/part-i-part-ii-part-iii-and-treasury-ministal-approval).
In general, I suggest that authorities delegate the task of devising STR indicators to the industry via SRO-s while actively taking part in such discussions (to raise ownership over such indicators). Another idea raised in Armenia is to set a requirement by which a reporting entity having come across with a transaction matching any of STR indicators should either (a) file an STR, or (b) explain in writing why it hasn done so. This might increase the effectiveness and accountability over implementing STR indicators. The problem, however, is that the indicators as such should then be defined very accurately not to overwhelm the work of operations/compliance.