What is score if your MLRO wont give receipt letter for internal STR. thx

On the one hand, I can understand that he/she might not wish to issue anything in case it finds its way onto files but I personally think that is being overly cautious and an acknowledgement can be such hat it doesn't name the client or person on whom the  report was filed, instead a date and reference number could suffice surely.  Your post didn't indicate how the internal STR was made.  Handwritten, typed, electronically etc as you might have an audit trail there that would, if called upon, show that you did report your suspisions.

What explanation has your MLRO given?  If they haven't given you an explanation then you should ask for one. 

Hello. Thx for your response. Report was written and no audit trail avaliable.

A receipt should be provided to the sender of the SAR.  This will provide the reporter with protection in case of investigation as it proves that the member of staff has submitted a report on a specific date and therby enables a rebut of any accusations of failing to disclose.  The onus of responsibility is passed to the MLRO. I agree that the best form of content will be a reference number and a reminder about Consent to transact and the tipping-off offence.

Staff should be made aware via Procedure Manuals of the timeframe that a response will be posted.  

I am an MLRO in a financial services business and cannot understand the lack of willingness to provide a receipt? 

Our procedures manual states a receipt will be provided to the reporter within 24 hours.  The content makes reference to the SAR number, which is only available to the MLRO and JFCU, and a reminder of the tipping off offence.  The reporter reminded to keep this receipt confidential, password protected and most certainly not to place it on any files.

As stated by the previous post, an acknowledgement receipt is your only proof of submitting a report.

If it were me I would take this to senior management / board level as this practice really should not be allowed to continue.  If word got out (as these things have a habit of doing) that this was the stance of the MLRO, it could seriously impede people submitting SAR's which in turn would not do the business any favours at all.

Why refuse to issue a receipt?? Why frustrate the audit trail and thereby any subsequent investigation/s??? At the very least an expanation should be provided.

Possibly a training requirement as the whole process of "reporting" has not been fully understood, particularly the implications.

If you can't get a receipt, write up a note that on such and such a day, you issued an internal suspicious activity report to the MLRO regarding X&Y and did not receive a receipt for the report.  Ask the MLRO to sign that.  If the MLRO refuses to sign that, place one copy in a sealed envelope with "confidential, only to be opened at the request of your name" and request that it be placed in your HR file.  Place a second copy in a sealed envelope and send it to the MLRO's boss.

In addition to the last post, you could also post a copy of the note to yourself via the recorded postal service, and don't open it when you receive it - that way, you have proof of date on the postmark and postal signed receipt.

To cover myself I would send a note to the MLRO via email(if there is an internal email system) indicating that the report was submitted (reference number etc).  This is a definite internal trail in my opinion.

Could I please ask for some input on a subordinate question to this one? The general consensus from previous posts seems to be that no record of an SAR should find its way into a client file. On the one hand, I can see the sense in that to ensure that only those who need to know do so, avoid the danger of tipping off etc. but, on the other, it strikes me that it could also have a downside. For instance, somebody other than the usual adminstrator doing work for a client or somebody conducting a client review could benefit from knowing that an SAR has been submitted in the past (albeit with specific detail restricted to the originator of the internal SAR and the MLRO). In light of that knowledge, an offhand comment from a client, small piece of information in the file or transaction request make take on a greater significance and lead to a suspicion that might not be the case otherwise. I'd be interested to hear others' views.

Perhaps rather than putting note of a SAR in the file which may have ramifications later - the risk rating might be higher forcing a review if any further transactions are to take place ...

Fair comment but might have limited impact if the client's risk rating is already higher (i.e. close scrutiny of all transactions would be a requirement anyway but without that extra "edge" you would have if you knew you looking at client where an SAR had been submitted in the past). If it was a standard client and you made it higher on the basis of the SAR, that might prompt questions from staff and could lead to a confusing situation whereby they know a client has been made higher risk but aren't allowed to know why?