Support for reporting entities in order to submit high-quality disclosures

This is a list of the main criteria that CTIF-CFI uses to assess the general quality of a disclosures¹, aimed at helping reporting entities improve the quality of their disclosures, which should also affect the effectiveness of CTIF-CFI’s analytical process.

The quality of a disclosure refers to criteria related to content as well as to its form, the latter may also include more technical aspects.

1.  The disclosure is submitted via the online reporting system (possibly via web service) or via the online disclosure form available on CTIF-CFI’s website.

2.  The disclosure is clear and complete

1. 1. the different elements of the disclosure are all present (if applicable)
   2. these are listed in the ad hoc sections of the disclosure
   3. the annexes of the disclosure contain all the documents that are useful for the analysis (a copy of the identity documents of customers who are natural persons and whose identity details cannot be checked in the National Register, the articles of association of foreign companies, account history in compliance with the uniform bank statement, supporting documents, judicial orders,…)

3.  Where applicable, it is explicitly mentioned that the disclosure complements a previous disclosure by the reporting entity and states CTIF-CFI’s reference given to the initial disclosure.

4.  The identification of customers, agents and/or beneficial owners is correct and complete

1. 1. it includes as much identification data as possible and at least the data required by the Law of 18 September 2017
   2. it complies with the data structure required for certain specific fields of the online disclosure (number of the National Register, business number, IBAN account number and nationality of the person involved)
   3. the identification data of the agents and beneficial owners are mentioned in the ad hoc sections of the disclosure, i.e. CTIF-CFI does not have to look for this data in the annexes
   4. the information on the line of business of customers is precise enough to determine the activity they actually carry out.

5.  The description of the suspicious transactions/facts is clear and precise

1. 1. the transactions/facts considered to be suspicious are clearly stated in the ad hoc section of the disclosure and mention the period and the total volume of the suspicious transactions as well as the main countries of origin and countries of destination of the funds
   2. in case of an online disclosure the suspicious transactions are listed in the structured table provided for this purpose (at least when there are not too many)
   3. the description of the suspicious transactions reflects the reported facts
   4. if the disclosure features a series of customers who carried out suspicious transactions, the link between them is explained clearly so CTIF-CFI can identify the main individual(s) on whom to focus its analysis.

6.  The disclosure is based on subjective elements from a genuine analysis

1. 1. the red flags that have led to the disclosure are clearly stated
   2. where applicable it is explicitly stated that the customer was questioned on the suspicious transactions/facts but that the customer did not want to reply or gave incomplete or unsatisfactory answers
   3. this information is in the ad hoc section of the disclosure regarding the indications of money laundering and terrorist financing (i.e. separately from the information related to the description of the suspicious transactions/facts).

7.  The disclosure takes place within a reasonable period of time.

Moreover, reporting entities must also comply with the guidelines issued by CTIF-CFI, i.e.

1. the guidelines for reporting entities: these provide the necessary assistance for reporting entities to comply with the obligation to disclose as a result of the Law of 18 September 2017 (these guidelines are available on CTIF-CFI’s website in French and Dutch);
2. (technical) guidelines on certain specific topics, including the use of certain keywords (available on CTIF-CFI’s website soon).

 ^[1] CTIF-CFI does not have the exclusive power to determine these criteria.