Podcast
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
