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Questions and Answers
A Reporting Entity is not required to submit a Terrorist Property Report to the FIU if it had no dealings with a listed person or entity.
False
A customer who refuses to produce personal identification documents is a definite indicator of terrorist activity.
False
A Reporting Entity is only required to submit a Terrorist Property Report to the FIU if it has dealings with a listed person or entity.
False
A customer who attempts to develop close rapport with staff is definitely a terrorist.
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The UN Sanction list must be checked on every application.
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A customer who conducts transactions at different physical locations within a short period is definitely a terrorist.
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A Reporting Entity has five (5) days to submit a report to the FIU.
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A customer who offers money for the provision of services is definitely a terrorist.
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The Supervisor Authority can keep its decision confidential.
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The penalty for an individual for non-compliance is up to $20 Million dollars and imprisonment for up to 5 years.
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The Suspicious Activity Report (SAR) is submitted to the FIU on the 15th of every month.
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The Board Policy of 2016 was established for External Breaches and sanctions.
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The threshold reports are submitted on the 20th of every quarter.
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Directors, Managers, and employees are not required to report their suspicions to the Compliance Officer.
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The penalty for a company for non-compliance is up to $60 Million dollars.
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The Compliance Officer decides whether or not to report a suspicious activity.
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Study Notes
Sanctions for Non-Compliance
- Administrative sanctions can be imposed by the Board of Governors (BOG) for non-compliance
- Written warnings, orders to comply, and prohibitions can be imposed on individuals and companies
- Suspensions, restrictions, or withdrawals of licenses can be imposed
- Supervisor Authority can publish its decision
Monetary Sanctions
- Individuals can be fined $5 to $15 million and imprisoned for up to 3 years
- Companies can be fined $15 to $40 million
Board Policy of 2016
- Established for internal breaches and sanctions
- Provides for sanctions for non-compliance under AML Act No. 13 of 2009
Criminal Sanctions
- Suspicious Activity Reporting (SAR) and Threshold Reports must be submitted by the 7th of every month
- Terrorist Property Reports must be submitted by the 7th after every quarter ends
- Failure to comply can lead to criminal sanctions
Legal Obligations
- Reporting entities have a legal obligation to report suspicious transactions to the Financial Intelligence Unit (FIU)
Suspicious Activity Reporting (SAR)
- Any transaction that causes a feeling of apprehension or mistrust should be considered for submission
- Reporting entities must report suspicious transactions to the FIU within three days
- Importance of client confidentiality, preventing tipping off, and prejudicing investigations
Suspicious Activity Report (SAR) Structure
- Compliance Officer (CO) investigates and decides whether to report
- Directors, Managers, and employees report suspicions to the CO
- Suspicious Transaction Report must be done if the transaction is flagged
- Report is submitted to the FIU within three days
Terrorist Property
- A terrorist or terrorist group includes anyone who has facilitated, participated in, or carried out terrorist activity
- Reporting entities must consult with the UN Sanction List to determine whether they are conducting business with designated persons or entities
Terrorist Property Report
- Evidence must be shown on every application that the UN Sanction List was checked
- Reporting entities must submit a Terrorist Property Report immediately if customer/client details match
- Quarterly Terrorist Property Report must be submitted to the FIU, even if no dealings with listed persons or entities
Triggers for Suspicious Activity
- Customer refuses to produce personal identification documents
- Customer does not want correspondence sent to home address
- Customer is quick to volunteer that funds are "clean" or "not being laundered"
- Customer attempts to develop close rapport with staff
- Customer insists that the transaction be done quickly
- Customer conducts transactions at different physical locations within a short period
- Customer transacts business with smelly or extremely dirty/soiled bills
- Customer performs two or more cash transactions of less than the threshold limit each within a short period
- Customer offers money for the provision of services
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Description
Quiz about the sanctions that can be imposed by the Bank of Ghana (BOG) for administrative non-compliance, including written warnings, suspension of licenses, and fines.
