Duration 2 days – 14 hrs
Overview
This practical course trains compliance, AML operations, and investigators on how to execute AMLC reporting end-to-end—from identifying reportable events, building a defensible case file, preparing CTR/STR submissions, and maintaining required records and supporting KYC evidence, to handling beneficial ownership (BO) identification and verification in investigations. It uses real-world workflows aligned with AMLC’s reporting/compliance submission guidance (including GoTRACS/ARRG) and AMLA/IRR requirements
Objectives
- Explain CTR vs STR obligations and apply decision rules to common scenarios under AMLA and related rules.
- Build a practical reporting workflow: detection → escalation → investigation → decisioning → submission → retention.
- Prepare an audit-ready case file (facts, chronology, evidence, approvals, disposition).
- Draft high-quality STR narratives (clear suspicion basis, typology indicators, linkage, and supporting documents), while observing confidentiality and anti–tipping off principles.
- Apply record-keeping requirements and retention practices for customer identification and transaction records.
- Identify and verify beneficial ownership and document BO evidence and rationale correctly (including BO red flags).
- Reduce reporting defects by using quality checks (completeness, consistency, timeliness, and traceability).
Audience
- AML investigators / case analysts / transaction monitoring analysts
- Compliance officers, MLRO support staff, reporting teams
- KYC/EDD teams involved in investigations and escalations
- Compliance QA/audit liaisons and team leads
- Operations risk and relevant control owners
Pre- requisites
- AML/KYC fundamentals (or completion of AML/CTF Fundamentals course)
- Basic familiarity with your onboarding journey and customer data fields (helpful, not required)
Course Content
Day 1 — Reporting fundamentals + CTR/STR decisioning
Module 1: AMLC reporting ecosystem & obligations
- Covered persons’ primary reporting duties and compliance submissions
- Reporting timelines and governance basics
Module 2: CTR vs STR—what triggers what
- Covered transactions (CTR): threshold concepts and aggregation logic (high level)
- Suspicious transactions (STR): suspicion grounds and practical indicators
- Common pitfalls (over/under-reporting, weak rationale)
Exercise: CTR/STR classification drill (10 scenarios)
Module 3: The investigation workflow
- Alert → triage → case opening → evidence gathering → disposition
- Case documentation standards and maker-checker controls
- Building a chronology and “decision trail”
Workshop: Build a case chronology from sample logs
Module 4: STR narrative writing
- What makes an STR “useful”: clarity, specificity, linkage, and completeness
- Structuring the narrative: who/what/when/where/how/why suspicious
- Confidentiality and anti–tipping off essentials
Lab: Draft a short STR narrative from a case pack + peer review
Day 2 — Record-keeping + Beneficial Ownership + submission quality
Module 5: Record-keeping & evidence retention
- What records to keep: customer ID/KYC, transaction records, investigation notes, approvals
- Retrieval readiness: how to store for audit/regulator requests
Workshop: “Evidence checklist” build for your organization
Module 6: Beneficial Ownership in practice
- Identifying BO and control persons; documenting verification approach
- BO verification process and risk-based depth
- BO red flags (complex structures, nominees, opaque control)
Lab: BO identification using 2 corporate structure exercises
Module 7: Submission readiness & quality assurance
- Pre-submission QC: completeness, consistency, attachments/supporting docs
- Common rejection/return causes and how to prevent defects (data quality, mismatches)
- Metrics: timeliness, defect rate, rework rate, aging
Module 8: Capstone simulation
- Teams complete: (a) CTR/STR decision, (b) STR narrative, (c) evidence pack, (d) retention checklist
