Suspicious Activity Reporting Policy¶
| Code | AML-006 |
| Domain | AML / Financial Crime |
| Owner | Chief Compliance Officer |
| Status | Draft |
| Applicability | Platform |
| Jurisdiction | NZ + AU |
| Business domain | BD07 |
| Review date | 2027-03-25 |
Regulations: AML/CFT Act 2009 · AML/CTF Act 2006¶
Purpose¶
Govern the obligations to file Suspicious Activity Reports, Suspicious Transaction Reports, Threshold Transaction Reports, and International Funds Transfer Instructions with the relevant Financial Intelligence Units.
Scope¶
All transactions and customer activity across NZ and AU that meet or may meet the filing thresholds or grounds for suspicion under the NZ AML/CFT Act and AU AML/CTF Act.
Policy statements¶
The platform SHALL file a Suspicious Transaction Report (STR) with the NZ Police Financial Intelligence Unit within three working days of forming a suspicion that a transaction is related to a serious offence or money laundering.
The platform SHALL file a Suspicious Activity Report (SAR) with AUSTRAC within three business days of forming a suspicion that a customer or transaction may be related to money laundering or terrorism financing.
The platform SHALL file a Threshold Transaction Report (TTR) with AUSTRAC for all cash transactions equal to or exceeding AUD 10,000 within the timeframe required by the AU AML/CTF Act.
The platform SHALL file an International Funds Transfer Instruction (IFTI) report with AUSTRAC for every international funds transfer instruction sent or received within the required timeframe.
All suspicious matter reports SHALL be reviewed and approved by the CO or a delegate before submission. The submission record SHALL include the analyst rationale and supporting transaction data.
The decision not to file a suspicious matter report following an escalated alert SHALL be documented and retained for seven years.
The platform SHALL maintain a tipping-off prohibition. No staff member SHALL disclose to the subject of a report or any third party that a report has been or may be filed.
STR/SAR filing capability SHALL be tested at least annually. Any failure in the filing pathway SHALL be escalated to the CO and remediated within 30 days.
Satisfying modules¶
| Module | Name | Mode | Description |
|---|---|---|---|
| MOD-013 | Real-time sanctions screener | ALERT |
Confirmed sanctions hit creates automatic SAR/STR draft and escalation to compliance |
| MOD-014 | List change propagation | ALERT |
New designation matches auto-escalated to compliance — no reliance on agent to check the list |
| MOD-018 | Alert case management system | LOG |
SAR decision trail — from alert to submission — fully auditable |
| MOD-037 | AUSTRAC / RBNZ AML reporting pipeline | LOG |
SAR submissions tracked from creation to acknowledgement — no submission gaps possible |
| MOD-048 | System decision log | LOG |
AML alert dismissals logged with analyst ID and reasoning — not a silent discard |
| MOD-052 | Role-scoped data access | AUTO |
SAR data accessible only to compliance and legal roles — segregation enforced at data layer |
Part of AML / Financial Crime · Governance overview
Compiled 2026-05-22 from source/entities/policies/AML-006.yaml