QFCRA issues STR and SAR programme guidance for QFC firms
QFC firms must evidence STR/SAR controls, MLRO escalation and QFIU reporting
QFCRA
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Change
QFCRA issued guidance requiring QFC firms to implement documented STR and SAR programmes within their AML/CFT control frameworks.
Why it matters
The guidance turns suspicious-transaction and suspicious-activity reporting into a documented programme obligation for QFC firms. Firms must connect transaction monitoring, customer screening, MLRO escalation, QFIU reporting, QFCRA notification, tipping-off controls and ten-year record retention into a tested AML/CFT framework.
Implications
- — QFC financial institutions, DNFBPs and designated token service providers must maintain documented STR and SAR policies, procedures, systems and controls — suspicious transactions, activities and attempted operations must be identified and escalated regardless of value.
- — QFC firms must give officers and employees direct access to the MLRO or Deputy MLRO for internal suspicion reporting — the MLRO function owns assessment, QFIU reporting, QFCRA notification and authority liaison.
- — QFC firms must notify QFCRA through Form Q07 after reporting to the QFIU and retain suspicious-activity records for at least ten years — STR information must be safeguarded to prevent tipping-off.
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