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Reference Materials and Relevant Websites

Suspicious Transactions Reporting to JFIU – Points to note

Insurance institutions (“IIs”) when fulfilling their statutory obligations to file a suspicious transaction report (“STR”) are encouraged to make reference to the reporting methods and advice available on the website of the Joint Financial Intelligence Unit (“JFIU”) , as well as the advice and observations from the JFIU set out below.

  1. Adopting the SAFE approach
    "SAFE" is a four-step approach which is Screen, Ask, Find, and Evaluate. Implementing an effective approach to identify and evaluate potentially suspicious transactions could help IIs in gathering necessary information for filing STR. IIs are encouraged to make reference to the SAFE approach as recommended by the JFIU when designing their procedures and approach in identifying and reporting suspicious transactions.
  2. Compiling STR with sufficient information
    Various types of information should be provided, with an appropriate level of detail, in STR in order for the JFIU to analyze and follow up, including the background information regarding the insurance policies involved, the information obtained through customer due diligence, and any explanation provided by the person involved in the suspicious transaction.  When reporting the name of a person involved in the suspicious transaction, the family name and given name of the person should be indicated, especially for foreigners.

    Any information stated incorrectly in STR, such as the date of birth of the person involved in the suspicious transaction and the reference number of the STR submitted previously, will make it more time-consuming for the JFIU to vet and process the STR.  IIs are reminded to compile STR with care.

    A list of details that STR should contain is presented under “What to Report in an STR?” on the JFIU’s website
  3. Use of STREAMS or proforma report for compiling and submitting STR
    STREAMS (Suspicion Transaction Report and Management System) is a web-based platform to assist in the receipt, analysis and dissemination of STR.  IIs are encouraged to input the details of STR with the use of STREAMS as it already contains all the necessary fields for compiling the information required by the JFIU, and it will minimize the need to follow up with the JFIU’s request for further information.  In addition, STREAMS provides the function of uploading supporting documents for the STR, eliminating the need for the reporting entity to print hard copy of these documents for submission.

    Alternatively, IIs may compile STR with the use of the proforma report available for download from the JFIU’s website, to provide as much relevant information to the JFIU as possible.
  4. Providing contact details and assigning a reference number to an STR
    To facilitate JFIU in processing an STR and giving feedback to the reporting entity, contact details such as contact person’s name, telephone number, email, etc. should be provided in the STR.  In addition, IIs are encouraged to assign a reference number to each STR filed such that JFIU may quote that reference number when giving feedback on a particular STR to the reporting II.

IIs are also reminded to take appropriate steps to ensure that any STR submitted by them contains accurate, sufficient information of the transaction and the person or entity involved, and a reasonably detailed analysis of the suspicion triggering the obligation to file the report. By providing as much relevant information as possible in the STR, IIs will minimize the need for the JFIU to request further information from them that is required for analysis and follow-up.