Purpose
Escalate and report unusual or suspicious activity through the prescribed FIU Curacao reporting channel while controlling tipping-off risk.
Scope
This procedure applies to internal case classifications, unusual transaction review, sanctions matches, temporary holds, refusals, restrictions and external FIU reporting.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Open compliance case | Open or update the internal compliance case when onboarding, sanctions screening, or transaction monitoring identifies a reportable concern. Spans three compliance domains: Client Onboarding, Sanctions Screening, Transaction Monitoring (KYT) | Case file |
| 2 | Classify case internally | Classify the case as SAR, STR, FFR, PNMR or another approved operational case label where useful | Case file |
| 3 | Treat labels as internal only | Internal SAR/STR/FFR/PNMR labels are case-management classifications only; external FIU submission is a UTR through the prescribed FIU Curaçao channel. Internal classifications do not represent separate external reporting categories | Case file |
| 4 | Collect supporting evidence | Gather chronology, client data, transaction data, screening data, wallet analysis, communications and investigation notes | Case file |
| 5 | Assess onboarding concerns | Request and assess additional documentation within ten days where appropriate, without allowing that period to delay a legally required report. If warranted, submit a UTR to FIU Curaçao within 24 hours | Chronology and reporting-timeliness evidence |
| 6 | Apply temporary hold/restriction | May pause, hold, refuse, restrict, or decline relationship/transaction/payment/transfer/settlement/wallet setup/release while Compliance reviews. Covers ML/TF/PF, sanctions evasion, fraud, false information, unexplained source of funds, suspicious wallet exposure, third-party payments, unusual transaction behavior. Measure must be proportionate, documented, and escalated without delay | Hold or refusal record |
| 7 | Handle confirmed sanctions matches | Apply legally required restrictive measures (blocking/freezing where applicable); escalate to Compliance without delay; assess and execute FIU Curaçao and CBCS reporting/notification obligations; document all actions including timing, ownership, rationale, outcome. MLRO or designated Compliance Officer coordinates | Restrictive measure record |
| 8 | Escalate to MLRO/Compliance | MLRO or designated Compliance Officer determines whether the matter can be cleared, needs additional info or EDD, must be refused/restricted, requires senior-management escalation, or must be reported/notified externally | MLRO decision |
| 9 | Submit UTR to FIU Curaçao | When suspicion is determined and reporting is required, submit UTR through the secure FIU Curaçao portal without delay and, for the onboarding workflow, within 24 hours of determination. All reports filed by MLRO or delegate | UTR submission confirmation |
| 10 | Separate FIU and CBCS obligations | Separately assess and record sanctions restrictive measures, FIU reporting, and CBCS supervisory reporting/notification; one action does not automatically evidence the others | Separate FIU and CBCS decision records |
| 11 | Control tipping-off risk | Avoid tipping off the client or any unauthorized person. Client communication must remain factual, limited, and consistent with legal and regulatory obligations | Tipping-off control evidence |
| 12 | Record case decisions | Record timing, owner, rationale, decisions, client communications, submissions, acknowledgements and follow-up actions. Document all temporary holds, refusals, restrictions, escalation decisions, investigation steps, outcomes, and reporting/notification actions | Case file |
| 13 | Retain complete case file | Retain the complete case file and keep reporting decisions under MLRO or authorized delegate control | Case file |
Evidence
- case file
- MLRO decision
- UTR submission confirmation
- hold or refusal record
- tipping-off control evidence
- chronology and reporting-timeliness evidence
- separate FIU and CBCS decision records
Relationships
- Policy: POL-AML-001 AML CTF CPF Compliance Manual
- Process: PRC-FCI-001 Financial Crime and Integrity
- Controls: CTRL-AML-005 Ensure FIU Reporting and Case Escalation Are Completed
- Manual coverage: sections 5.1-5.7 and 14.4.1.3.
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Design status: implemented from approved AML/CTF/CPF Compliance Manual version 2.2
History
- 2026-07-26: Added internal/external classification boundaries, onboarding and reporting timing, restriction options and separate FIU/CBCS decision records after a full manual rescreen.
- 2026-07-26: Created from the approved AML/CTF/CPF Compliance Manual version 2.2.