Prescribed Transaction Reporting

Department of Internal Affairs reporting entities

Recently AML Partners sort guidance from the Department of Internal Affairs (DIA) with regard to the requirements for prescribed transaction reporting for reporting entities they supervise.  

DIA confirmed that reporting entities are required to file a prescribed transaction report for payments to/from overseas for $1,000.00 or more.

DIA Example:

- Distribution of estates where beneficiaries live overseas. 

- Payment is made from my trust account. 

- Do I report or does my bank? 

In this scenario it appears you are acting as the originating institution for an international wire transfer. As such you have to submit a prescribed transaction report (PTR) to the FIU. The bank is an intermediary institution and does not have to report on the transaction.

Financial Markets Authority (FMA) reporting entities

The FMA has published the following on its website:

Am I required to file a PTR?

In the case of an international wire transfer, the first reporting entity to transfer funds, and the last reporting entity to receive funds, must do a PTR. We expect that a reporting entity that receives and/or passes on instructions from a client to do an international wire transfer, but does not actually transfer the funds, is not required to do a PTR. This means that international wire transfers carried out by a bank on behalf of another reporting entity will be reportable by the bank.

If an international wire transfer is settled outside the banking system (for example if a reporting entity carries out a transaction on behalf of a client and as a result money is made available to a beneficiary at another entity in another jurisdiction) the reporting entity must submit a PTR.

AML Partners recommends that reporting entities seek guidance from their respective AML/CFT Supervisor for their particular business to ensure compliance. (AML Partners)