On 6th November, an article on Linkedin from Steele Compliance Solutions Inc says that there are essentially 2 questions that need to be answered when making a SAR filing decision: are the transactions in line with the account’s purpose, profile, or nature of business?; is there any outside information that would increase the risk level related to the transaction or parties involved (this could be negative news, political exposure, sanctions, a high number of prior investigations, subpoenas, etc.)?  It put together a flowchart to outline how the above questions could be integrated into the decision-making process at its most basic level.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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