Suspicious Transaction Reporting (“STR”) policy and procedures

Based on the guidelines issued by the Labuan FSA on Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) for Trust Company Sector, TradeUltra Ltd (the “Company”) has implemented the following internal STR policy and procedures to monitor suspicious transaction and to address its reporting obligation.

The following policy and procedures are developed for identifying, evaluating and investigating, reporting as well as record keeping of potential suspicious situation/transactions (including attempted or proposed):


The Company’s employees need to ensure that all potential/ existing customers do not engage in criminal activity, money laundering or terrorist financing. They must monitor carefully at all unusual transactions to see if there is anything suspicious about the customer.

There are many reasons why an employee might become suspicious about a transaction/activity. Often it is just because of something unusual for a business, maybe a customer behaved strangely, or perhaps customer made unusual requests that did not seem to make sense.

The Company’s employees may be guided by providing regular training and may be guided by example provided in the Company’s internal measures for “Mechanism or Red Flag to indicate occurrence of suspicious transaction”, to assist them in identifying any attempted or proposed suspicious transaction.

Evaluating and Investigating

Whenever a company’s employee detects any “red flag” that fits the list indicated above or senses any unusual activity/transaction, he/she must directly inform the AML Compliance Officer (“Compliance Officer”) without delay.

Upon receiving any internal suspicious transaction report from the company’s employees, the compliance officer will first evaluate the grounds for suspicion and he will make an initial decision of whether a customer/transaction is potentially suspicious.

The employee may be required to investigate the customer/transaction further under the direction of the compliance officer. This may include gathering additional information from the customer or from third party sources to assist in determining whether the customer/transaction is indeed suspicious and to eliminate “false positive”.

These procedures should reflect the principle of confidentiality, where employees are to ensure that investigation is conducted swiftly and that reports contain relevant information and are produced and submitted to the compliance officer in a secured and confidential manner, within 5 working days from the commencement of investigation.

The company’s employees must not disclose to customers or anyone else that they are subject to investigation. If the employee has reason to believe that performing customer due diligence process would tip off the customer, he/she must alert the compliance officer of such case for immediate attention.


Internal suspicious transaction reports provided by the company’s employee must be reviewed by the compliance officer within 3 working days from receiving such report.

The compliance officer is to complete his review within 5 working days. Under the circumstances where a report requires further investigation, the timeframe can be exceeded up to a month.

Once the compliance officer has finished his review of the details, he should determine if that particular event rendered an attempted or proposed suspicious transaction.

The compliance officer will consult with the Company’s Board of Directors to make the decision as to whether the customer/transaction is suspicious and whether a filing with the appropriate government authorities is necessary.

The compliance officer will promptly submit the suspicious transaction report within the next working day, from the date the compliance officer establishes the suspicion.

The fact that a report has been made is confidential. The compliance officer, as well as the company’s employees shall ensure that in the course of submitting the suspicious transaction report, such reports are treated with the highest level of confidentiality. No one, other than those involved in the investigation and reporting should be told about a suspicious transaction report, except for the law enforcement or other competent authorities.

However, under the circumstances where the compliance officer decides that there are no reasonable grounds for suspicion and no suspicious transaction reports is necessary to be submitted to the relevant authorities, the compliance officer must document and file the decision, supported by the relevant supporting documentary evidence, which will be made available to the relevant supervisory authorities upon request.

Record Keeping

The compliance officer shall maintain a complete file on all internally generated reports and any supporting documentary evidence, regardless of whether such report has been submitted. In the case of a filed report, a back up documentation is necessary.

The following are some of the information maintained for record keeping, which includes but is not limited to:

Maintain a record of identifying information provided by the customer.
Where the company relies upon a document to verify identity, the company must maintain a copy of the document with clear evidence that the company relied on and any identifying information it may contain.
Record the methods and result of any additional measures undertaken to verify the identity of the customer.
Record the resolution of any discrepancy in the identifying information obtained.
The nature or circumstances surrounding the transaction; and
Business background of the person conducting the transaction that is connected to the unlawful activity.

All transaction and identification records are to be retained for a minimum period of 6 years, following the completion of transaction.

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