Businesses, especially those susceptible to exploitation by financial criminals, are at the forefront of the fight against money laundering and terrorist financing. Their AML/CFT obligations include monitoring transactions for signs of suspicious activity and filing suspicious transaction reports with the Financial Intelligence Analysis Unit.

These reports supply the data the FIAU needs to provide money laundering and terrorist financing intelligence to law enforcement agencies.

Possibly, an MLRO’s biggest dilemma is initially to determine what is suspicious and whether the case should be reported to the FIAU.

Apart from discussing the responsibilities of the MLRO vis-à-vis identification and reporting of STRs, this presentation will mainly focus on presenting case studies in order to tackle the three concepts of Knowledge, Suspicion and Reasonable Grounds to Suspect, as well as looking at the aftermath of filing a report.

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John Scicluna is currently an AML/CFT Regulatory and Compliance Consultant working closely with WH Partners. Previously he was the Head of Compliance with the same firm, WH Partners. A career banker for 38 years, he has held posts in many areas of one of the largest banks in Malta, 17 of which were as Head of Financial Crime - Money Laundering Reporting Officer. He formed part of the European Banking Federation Prevention of Money Laundering and Fraud Committee on behalf of the Malta Bankers’ Association.  He was also assigned roles within the Internal Audit Department managing investigative and analytical assignments. John is a visiting speaker in a number of local and international seminars and training events covering AMLCFT and financial crime related topics.