There are three methods available for submission of PTRs to the FIU:
- Manual entry using the online goAML web forms
- XML file upload via goAML web
- Business-to-business (B2B) fully automated submission
Option 1 requires no technical development by a reporting entity.
Options 2 and 3 are automated methods which will require technical development from a reporting entity, or a third party software solution provider.
Option 1 – Manual entry using the online goAML web forms
This option requires a user to log in to the goAML web portal and complete an online form (similar to the Suspicious Activity Report and Suspicious Transaction Report forms).
No technical development is required by a reporting entity, however staff will need to be trained on how to use and correctly fill out the web forms.
Option 2 – XML file upload via goAML web
This option requires a reporting entity to develop a solution that may link multiple databases together, depending on where the required information is held. A user then needs to manually upload a valid XML file (or ZIP file containing multiple XML files) relating to multiple transactions.
Please note: International Funds Transfers (IFTs) and Large Cash Transactions (LCTs) must be contained in separate files – i.e. one XML file can contain multiple IFTs, but not a combination of IFTs and LCTs).
This option may be beneficial for a reporting entity if they expect higher volumes of transactions, and/or already has systems in place that successfully integrate the required information for PTRs.
Option 3 – Business-to-business (B2B) fully automated submission
This option enables a reporting entity to send PTRs automatically (most likely on a daily basis) to the FIU.
Like option 2, it requires initial investment by a reporting entity in developing a solution that links multiple databases together, depending on where the required information is held.
Once the B2B solution is successfully in place, no manual user intervention is required, however a monitoring process will need to be implemented to ensure that reports are successfully processed.
Criteria for automated submission (XML upload or B2B)
To develop an automated PTR solution, reporting entities should carefully consider whether:
- The required information is currently captured by business processes and systems, and where and how the information is stored.
If the information is captured manually or in paper form, it will be difficult to generate an XML file.
- Your reporting entity has the appropriate technical expertise and resources to prepare and maintain the solution (both technical and business/compliance).
Developing an automated solution requires specialised technical expertise. If reporting entities do not have (or have access to) IT expertise, developing an automated solution will be challenging.
Reporting entities may wish to consider engaging with a third party software solution provider to develop an automated solution for submitting PTRs to the FIU.
- There is appropriate budget available for preparing and maintaining a technical solution.
Automated submission of PTRs to the FIU requires investment in technology and resources to prepare and maintain the automated solution. Alternatively, a third party software solution provider may be a viable option for your reporting entity.
- The anticipated volume of transactions that will need to be reported justifies investment in an automated solution.
Developing an automated solution for the submission of PTRs to the FIU allows reporting entities to submit many transactions at one time. If a reporting entity does not expect to be submitting high volumes of transactions, there may not be benefit in investing in an automated solution.