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F. Suspicious Transaction Monitoring and Reporting

1. VASPs shall employ methods which are appropriate to their particular circumstances and VA Activities to continuously monitor business relationships with clients to identify any Suspicious Transactions. Such methods shall ensure that no “tipping-off” or similar offence occurs. Such methods shall also ensure all Suspicious Transactions are immediately reported to the MLRO, in order for the MLRO to meet the requirements of this Rule III.F. VASPs are required to document, obtain Senior Management approval for, and periodically review and update such methods to ensure their effectiveness.
2. VASPs shall put in place and regularly update indicators that can be used to identify possible Suspicious Transactions.
3. Upon suspicion or reasonable grounds to suspect that the proceeds of a transaction are related to a crime, or the attempt or intention to use funds or proceeds for the purpose of committing, concealing or benefitting from a crime, the MLRO shall be responsible for—
  a. immediately reporting to the UAE FIU and VARA such Suspicious Transactions in accordance with Rule III.F.4 of this Compliance and Risk Management Rulebook;
  b. responding to all additional information requests from the UAE FIU and/or VARA promptly and in any event within forty-eight [48] hours of such requests;
  c. undertaking any additional actions as may be requested by the UAE FIU and/or VARA within any specified timeframe in such requests; and
  d. in the event the MLRO is not the same individual as the CO, immediately reporting to the CO that a Suspicion Transaction report has been made, provided that the provision of any such report would not be considered “tipping-off” or a similar offence under any applicable laws or regulations.
4. All reports regarding Suspicious Transactions shall be made—
  a. to the UAE FIU and VARA on the GoAML platform or by any other means approved by the UAE FIU and/or VARA; and
  b. in accordance with any Guidance which may be issued by VARA from time to time.
5. VASPs shall continue monitoring [on a near real time basis where appropriate] any transactions which are the subject of a Suspicious Transaction report.