Purpose
Ensure FIU reports contain the information required for analysis and follow-up.
Normative
Bitkaya shall include all reasonably available mandatory data in each FIU report, including client and counterparty identity, identity-document data, transaction nature, time and place, amount, destination and source of assets, reporting rationale, the identity of any person acting for or on behalf of the client, relevant high-value goods and applicable failed-CDD reasons.
Descriptive
The 2024 amendment expanded Article 11(2) to cover counterparties, persons executing a transaction, descriptions of high-value goods and reasons why CDD did not achieve the required result or could not be completed.
Source reference: MOT Article 11(2), as amended by P.B. 2024, no. 41, Article II(F).
Assurance Assertions
- The FIU report form or checklist covers every current statutory data field.
- Missing information is identified and explained rather than silently omitted.
- Failed-CDD reporting captures the reasons required by the amended provision.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Related requirement: REQ-LID-005 Report Failed CDD and Suspicious Circumstances
- Procedure: PROC-AML-005 Perform FIU Reporting and Case Escalation
- Control: CTRL-AML-005 Ensure FIU Reporting and Case Escalation Are Completed
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from MOT Article 11(2), including the 2024 expanded report fields.