Central Bank of Ireland STR Findings: Poor Practice and Expectations

Most guides to Irish suspicious transaction reports (STRs) explain who must file and how. This one looks at the other side: what the Central Bank of Ireland found when it inspected firms and what it said good looks like. The source is the Central Bank's Anti-Money Laundering Bulletin, Issue 2, published in November 2017, which gives guidance on STRs and an update on AML developments. If you need the filing basics first, read our guide to suspicious transaction reports in Ireland.

What the Central Bank found

According to the bulletin, designated persons generally understand their reporting obligations, which the Central Bank links to rising STR volumes in recent years. It also found that some sectors rely too heavily on manual transaction monitoring, which can delay reporting or cause suspicious activity to be missed. Other sectors have invested significantly in automated monitoring, which the bulletin treats as the stronger approach. It notes that the Financial Action Task Force's mutual evaluation of Ireland called for more sophisticated AML tools in some sectors.

Poor practice the Central Bank identified

• Incomplete procedures: operational procedures that omitted steps for escalating suspicions to the money laundering reporting officer (MLRO), reporting to the authorities, and guidance on tipping off.
• Procedures that do not match practice: suspicions raised verbally or by email rather than on the required internal form, and MLROs not always acknowledging internal reports.
• Unvalidated monitoring: transaction monitoring systems rarely reviewed or validated, even when they generated excessive alerts or none at all.
• Thin MLRO assessments: records lacking detail on what prompted the suspicion, what investigation followed, and why the suspicion was reported or discounted.
• Delay: unexplained delays in investigating and reporting.
• Poor report content: STRs that lacked the detail the authorities need, such as customer details, transaction dates and amounts, or the reason for suspicion.

What the Central Bank expects

The bulletin sets out expectations under six headings:

• Internal reporting: procedures should cover all reporting requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, be readily available to staff, and match what happens in practice.
• The MLRO: the MLRO should formally acknowledge internally raised suspicions and document the reasoning behind each decision to report or discount.
• Monitoring: transaction monitoring systems should be reviewed regularly to confirm they work effectively.
• Quality of reports: STRs should contain all required information and be filed without delay.
• Records: firms should keep records of what triggered the suspicion, any further monitoring or investigation, whether the matter was reported, and the rationale.
• Training: staff training should cover the internal reporting procedure and how suspicions are reported to the authorities.

Timing and scope, as summarised in the bulletin

The bulletin summarises section 42 of the 2010 Act as requiring suspicions to be reported as soon as practicable. Where a suspicion arises before or at the time of a transaction, the STR should be filed immediately. Some analysis may be needed to reach a determination, but it should be done without delay. The bulletin says no minimum monetary threshold applies and that attempted transactions are covered. Where a suspected predicate offence is identified, a separate report should go to An Garda Siochana, and the STR should state that this has been done.

goAML registration

The bulletin says that from June 2017, STRs to the Financial Intelligence Unit must be submitted electronically through goAML, and firms must register on the goAML website first. The Central Bank expects all designated persons to be registered. Firms receive an automatic acknowledgment when an STR is accepted, and later communication about individual STRs takes place through the goAML Message Board. The Revenue Commissioners accept a printed copy of the goAML STR by post.

Our suggestions for an STR file

These are Learnsignal's suggestions, not Central Bank requirements. Use one internal reporting form and make sure every suspicion is on it. Give the MLRO a standard note that records the trigger, the enquiries made, the decision and the reason. Date-stamp each step so delay can be explained. Check each STR against a short list of must-have fields before it goes out. Test your monitoring rules at least once a year and keep the results. For a fuller view of how the Central Bank supervises these areas, see our guide to Central Bank of Ireland AML supervision. Training is available through Learnsignal CPD.

What we could not confirm

The bulletin is from November 2017, and we have not checked whether the Central Bank has issued later guidance on STRs that replaces or updates it. It gives no figures on STR volumes. The goAML and reporting arrangements it describes may have changed, so check the Financial Intelligence Unit and the Central Bank for current requirements. The timing points above are the bulletin's summary of section 42, and we did not read section 42 itself.

Frequently asked questions

Is there a minimum amount before an STR is required?

According to the Central Bank's bulletin, no minimum monetary threshold applies, and attempted transactions are covered.

Must the MLRO record why a suspicion was not reported?

The bulletin expects the MLRO to document the reasoning behind each decision to report or discount a suspicion.

How are STRs submitted?

The bulletin says STRs must be submitted electronically through goAML from June 2017, after registering on the goAML website.