Asset Management & Investment Funds Q&A - Aug 2020

Question

Is the method for submitting AML/CFT Suspicious Transaction Reports (STRs) to Revenue changing?

Answer

Yes.

From 7 September 2020, Revenue will introduce changes to how STRs are submitted.

• Reporting Entities and Money Laundering Reporting Officers (MLROs) will be required to submit all STRs to Revenue, using Revenue's Online Service (ROS) only.
• Revenue will no longer accept hard copy (paper) STRs from that date onwards.
• Reporting Entities will continue to submit STRs to both An Garda Síochána's Financial Intelligence Unit (FIU) via GoAML and to Revenue as dual reporting remains a requirement.

Enhanced online services will allow Reporting Entities to:

• Complete and submit an online form detailing suspicious activity. This file can be saved and later uploaded to An Garda Síochána's FIUs GoAML system.
• Upload single or multiple STR returns in XML format. Reporting Entities can also firstly complete the form in An Garda Síochána's FIUs GoAML system and download the generated XML to upload in Revenue.
• Save attachments.
• Receive on-line acknowledgements of STRs submitted to Revenue.

Reporting Entities must firstly be registered for ROS and have a digital certificate and can then register for STR Reporting.

We would recommend that registration be completed in advance of any requirement to file an STR.

For more information in relation to this topic please speak with your usual contact on the A&L Goodbody Asset Management & Investment Funds team.

Date published: 1 September 2020