Draft and file an STR

Filing a suspicious transaction report is a two-person job in FlowSentry. The investigator records suspicion and drafts the report; the MLRO (or the Deputy MLRO) reviews it and decides. FlowSentry then builds the goAML report, checks it, and tracks its hand-off to the Financial Reporting Centre (FRC). This tutorial covers both sides.

Before you start

• Investigator: Analyst, Senior analyst, MLRO or Deputy MLRO role, working an open case. See Investigate an alert end to end.
• Decider: MLRO or Deputy MLRO role, with an authenticator app or passkey enrolled for step-up.
• The case subject should be a customer whose KYC record is loaded; the report draws the subject's details from it.
• The two people must be different. If the MLRO recorded the suspicion, the Deputy MLRO decides it.

Part 1: The investigator drafts the report

Record suspicion

1. In the case, open Suspicion & STR.
2. Enter your Grounds for suspicion — the facts that lead you to suspect money laundering or terrorist financing — in at least 20 characters.
3. Select Record suspicion. The suspicion clock starts (your institution sets it in business days) and MLRO decision due shows the deadline. The case appears on the MLRO's workbench.

Choose the transactions

1. Open the Transactions tab.
2. Tick each transaction the report must include.
3. Select Save STR selection. The STR draft panel shows how many transactions are selected.

Write the narrative

1. Back on Suspicion & STR, under STR draft, pick the Report type:
   • STR — suspicious transaction(s) when you report specific transactions;
   • SAR — suspicious activity (no transactions) when the concern is activity rather than particular transactions.
2. Select Draft narrative with AI. The assistant drafts a Who / What / When / Where / Why / How narrative, a reason line and the evidence it cites, using pseudonymised data.
3. Select Use draft to place it in the Narrative field. The badge reads "AI draft — edit before saving". If AI is unavailable you get a rules-based draft instead.
4. Edit the narrative until it is accurate, specific and in your words. Check names, dates and amounts against the records.
5. Tick the Report indicators that apply.
6. Select Save STR draft.

Tip: Write for an FIU analyst who has never seen your institution: who the subject is, what they did, when and through which channels, why it is unusual for them, and what you checked.

You can keep refining the draft until the MLRO decides.

Part 2: The MLRO decides

1. Open Work › MLRO decisions (/approvals). The page lists every suspicion Awaiting a decision, with figures for items Due within 24 hours and any Report failures.

2. Open an item. Review the Narrative, Grounds, Indicators, Transactions to report, the Subject, when the suspicion was formed, who recorded it and the evidence count.

3. Select Check goAML readiness. FlowSentry builds the report without filing it and shows:

   • every validation finding, with the field to fix and how to fix it;
   • a data mapping table of what was filled from your data and what is missing.

   The card already shows Ready to file or the number of errors when the page opens. Each error names the field, what is wrong and where to fix it, with a link to the case tab or the customer record. File STR stays disabled until the check passes with no errors; warnings do not block filing. Fix the underlying data (for example the transactions selected for the STR, or a missing date of birth on the customer record) rather than editing the report, then reload the page or select Check goAML readiness again.

4. Decide:

   • File STR — FlowSentry asks for step-up. Enter your authenticator code or use your passkey and confirm. The decision is recorded and the goAML report is generated from it.
   • Return — sends the case back to the investigator. In Return to the investigator, say What more is needed. The suspicion and its clock stay on record; the investigator updates the case and uses Resubmit to the MLRO.
   • Do not file — in Decide not to file, record the Grounds for not filing and select Record no-file decision. The decision and its grounds go to the Internal no-file register.

If you recorded the suspicion yourself, the buttons are disabled with the message "You recorded this suspicion — another decider (the designated deputy) must decide it."

Note: From the moment a case involves an STR it is STR-restricted. Only STR-privileged roles (MLRO, Deputy MLRO and Auditor) and the people already on the case can see it. This is FlowSentry's tipping-off control.

Part 3: Hand the report to the FIU

FlowSentry prepares, validates and tracks filings. Submission to the FRC is an upload to the goAML portal by an authorised officer.

1. Open Reporting (/reporting). The figures at the top show STR awaiting submission, STR in correction and Overdue filings.
2. In the STR register, select View XML to read a report, or Download watermarked XML.
3. Under FIU portal hand-off, select the reports to send, then Download XML bundle (or Download hand-off package). These actions need MLRO authority and a fresh step-up.
4. Upload the bundle to the goAML portal.
5. Back in FlowSentry, select the reports and Mark selected as uploaded, recording the FIU reference the portal gives you.

Every view and download is recorded in the audit trail. The page also tells you which goAML schema a report was validated against.

If the FIU rejects a report

1. Select the report and Record rejection with the FIU's reason.
2. Use Return for correction so the case can be corrected.
3. The replacement report is approved by a different MLRO or deputy before it is handed off again.

What the audit trail shows

The audit trail names both people: the investigator who recorded the suspicion and drafted the report, and the MLRO who decided. Decisions, returns, no-file grounds, downloads and portal references are all attributed and time-stamped.

Related

• MLRO guide
• MLRO and Deputy MLRO
• Compliance and governance guide