Recent amendments to the serial 2 and 4 of the Third Schedule of the Anti-Money Laundering and Countering the Financing of Terrorism Act 2020 (“AML/CFT Act”) now require reporting entities under the AML/CFT Act to file Cash Transaction Threshold Reporting (“CTTR”) and Wire Transfer Transaction Reporting (“WTTR”) with the Financial Intelligence Unit Seychelles (“FIU”), as per the following:
- REPORTING THRESHOLD APPLICABLE TO WIRE TRANSFERS
“Every financial institution that sends domestically or cross-border or receives cross-border wire transfers, including electronic fund transfers, shall report all wire transfers of SCR50,000 or more of the equivalent money in the currency of other countries.”
- REPORTING THRESHOLD APPLICABLE TO BUREAU DE CHANGE
“Every Bureau de Change, including banks acting as Bureau de Change for forex trading in respect of persons who are not their customers shall report all transactions of its customers involving SCR 5,000 or more or the equivalent money in the currency of other countries.”
Revised FIU Guidelines and Reporting Templates
Further to the above legislative amendments, the FIU has revised its guidelines and reporting templates in relation to both WTTR and CTTR. The revised guidelines and reporting templates can be accessed here.
Submissions to the FIU
The submissions based on the amended provisions of the AML/CFT Act shall commence on 1 May 2021. All submissions shall be made using the revised Forms, which shall include retrospective cash transactions or wire transfers, that have been effected on or after 5 March 2021.
Please note that Threshold Reporting is not a new obligation. Therefore, all reporting entities which are currently submitting Threshold Reports to the FIU are required to continue with their submissions, as per the current established procedures, until 30 April 2021.
What is a Threshold Report?
A Threshold Report is a report that reporting entities are required to file with the FIU for executing cash transactions or wire transfers above the prescribed threshold limit.
The threshold reporting obligation is clearly defined in the AML/ CFT Act 2020, Section 5 of the AML/ CFT Act creates the obligation on reporting entities to file CTTR and WTTR with the FIU in the manner prescribed by the FIU.
Our Team at FiveComply can assist you comply with the abovementioned obligations. Do not hesitate to contact us.