LFIs should have mechanisms to inform the Board of Directors (or a committee of the Board) and senior management of compliance initiatives, compliance deficiencies, STRs, SARs, or other regulatory reports filed, and corrective actions taken. LFIs should also develop and maintain a system of reporting that provides accurate and timely information on the status of the AML/CFT program, including statistics on key elements of the program, such as the number of transactions monitored, alerts generated, cases created, and STRs, SARs, or other report types filed.

Employees should report the number and types of STRs, SARs, or other regulatory reports filed to the Board of Directors or a Board-designated committee. While employees are not required to provide actual copies of STRs, SARs, or other regulatory reports to the Board (or a committee of the Board), such notifications should contain sufficient information to enable the Board or its committee to provide appropriate oversight over the LFI’s AML/CFT program. Where an individual filing documents activity that poses a particular risk, management may provide a copy of the report to the Board or Board-designated committee. Where appropriate, the suspicious activity or transaction underlying the filing of an STR, SAR, or other regulatory reports should be communicated to those individuals responsible for managing the risk associated with the customer and/or activity that is the subject of the STR, SAR, or other regulatory reports in order to permit such employees to respond appropriately to the AML/CFT risks identified. Although all such communications are subject to the confidentiality restrictions, it should be noted that the confidentiality requirement does not pertain to communication within the LFIs or its affiliated group members (foreign branches, subsidiaries, or parent company) for the purpose of sharing information relevant to the identification, prevention, or reporting of suspicious transactions and/or crimes related to money laundering and the financing of terrorism and illegal organisations, according to Article 39.1 of the AML-CFT Decision (also referenced in Section 5. Confidentiality and Prohibition against “Tipping Off”).