Regulatory reporting: suspicious transaction reports and case data
The hardest part of regulatory reporting is not writing the report, but gathering the data that goes into it. The MASAK reporting form defines the fields for each section, and most of these fields reside in other systems of the institution rather than the monitoring system itself. In Truvali, the report draft is not filled out from scratch on a separate screen: it is generated directly from the case itself.
Regulatory reporting is the process where an obliged party reports suspicious transactions and situations to the competent authority and submits its periodic reports. The report is merely an output: the real work lies in properly collecting the data that will generate that report during the investigation. Data that is not collected in real time cannot be fabricated at the moment of reporting.
What fields does the reporting form require?
The MASAK reporting form consists of sections for obliged party details, report details, natural person details, legal entity details, suspicious transaction details, account details, suspicion category, and description, with defined fields for each section. Most of these fields do not reside within the monitoring system, but in other systems of the institution.
| Report component | Source |
|---|---|
| Transaction details | Transaction record: amount, parties, channel, time |
| Customer information | Onboarding file, identity verification, risk class |
| Triggering rule | Rule identity and its version at that moment |
| Suspicion category | Taxonomy field carried by the case |
| Investigation justification | Evaluation of the person who closed the case |
| Evidence | Documents, screening results, relationship network findings |
What do the three rules of the form require?
Non-monetary events are also reported. Matters that do not contain monetary value, such as suspicious account openings and closures, safe deposit box visits, and guarantee or power of attorney transactions, are written in the description section of the form, leaving the suspicious transaction section blank. The case must also carry non-monetary events.
A single report can cover a date range. If the suspicion is based on multiple transactions within a certain date range rather than a single transaction, the total amount and the date range are reported together as a multiple transaction. The case must be able to aggregate transactions within a range and present them as a single line item.
Channel and type distinctions are preserved. If suspicious transactions are concentrated in different channels, branches, or types, the form section can be repeated separately for each cluster. The case must be able to generate separate clusters based on channel and type.
The guideline also explicitly states that writing all financial transactions of the customer with the obliged party that are not deemed suspicious into the form is not required. In other words, the report carries a selection, not a full dump, and the justification for that selection must reside within the case.
How is the suspicion category determined?
When reporting, the suspicion is placed into one of the 38 categories in the MASAK reference table, and each category is mapped to the relevant legal regulation. Usury and POS usury are linked to Article 241 of Law No. 5237, while encouraging or mediating prostitution is linked to Article 227.
If case management operates with its own free-form tags, this mapping is done manually at the moment of reporting and debated every single time. When taxonomy is a native field of the case, the report finds it ready.
What is the threshold for reports with a suspension request?
The regulation based on Article 19/A of Law No. 5549, titled "Suspension of transactions", governs the suspension of transactions based on a report. Guidelines set a clear threshold for this: there must be documents or serious indications supporting the suspicion, rather than mere suspicion, that the asset subject to the transaction is related to the crime of money laundering or financing of terrorism. A suspension request is therefore different from an ordinary report, and the quality of the evidence carried by the case is directly decisive.
Application procedures and all submissions regarding suspicious transaction reports are carried out electronically through the MASAK.Online system.
How does Truvali address this?
The report is born from the case. The report draft is not filled out from scratch on a separate reporting screen. The date range, total amount, channel and type distinction, party information, and suspicion category already reside in the case. You state what you want in your own words, and the draft is compiled from the data in the case: every figure remains linked to the case it originated from. Details are on the automated reporting page.
Non-monetary events are first-class citizens. The event model recognizes financial and non-financial events separately. Events without a monetary amount, such as account opening, session, device change, and document upload, enter the rules and are linked to the case: matters to be written in the description section of the form are recorded this way.
The rule version is recorded. Which version of which rule triggered the event is stored alongside the event. When asked which rule set generated a report from a year ago, the answer is on record. The rule engine page explains this aspect.
The chain of evidence and decision is linked to the case. Information on who decided, with what authority, using which data, and when is written to the immutable audit trail. The approval workflow is not limited to a single second signature: approval policies, multi-signature decisions, and delegation of authority can be defined, with the delegation itself recorded along with its documentation. Details are on the maker-checker, authorization, and audit trail page.
Reports in institutional format are generated from the same data. Alongside regulatory reporting, the institution's own internal reports are also generated from the same source. Report definitions are made without code, and the results are saved and repeatable.
Deciding not to report is also a decision
During an audit, the question asked is often "why did you not report?", and the answer must reside within the case. When the case was opened, snoozed, and closed is also on record: this record is for both internal tracking and auditing. The case workflow is on the alert and case management page, and the investigation itself is on the source of funds investigation page.
The format and recipient vary by country: the Türkiye framework is on the MASAK obligations page, and the European Union side is on the AMLA and EU regulations page.
Source
MASAK sectoral suspicious transaction reporting guidelines and Law No. 5549 on Prevention of Laundering Proceeds of Crime.
This page does not constitute legal interpretation: it conveys the procedures contained in the guidelines. The reporting workflow is configured according to the institution's own obligations.
Common questions
- How is the report draft prepared?
- It is not filled out from scratch on a separate reporting screen: it is generated directly from the case itself. The date range, total amount, channel and type distinction, party information, and suspicion category already reside in the case.
- Are all transactions that are not deemed suspicious included in the report?
- No. The guideline does not require writing all financial transactions of the customer with the obliged party that are not deemed suspicious into the form: the report carries a selection, not a full dump, and the justification for that selection resides within the case.
- Are events with no monetary value reported?
- Yes. Suspicious account openings and closures, safe deposit box visits, and guarantee or power of attorney transactions are written in the description section of the form, leaving the suspicious transaction section blank.
- Can a single report cover multiple transactions?
- Yes. If the suspicion is based on multiple transactions within a certain date range, the total amount and the date range are reported together as a multiple transaction.
- How is the suspicion category determined?
- It is placed into one of the 38 categories in the MASAK reference table, and each category maps to the relevant legal regulation: for example, usury and POS usury are linked to Article 241 of Law No. 5237.
- What threshold applies to reports with a suspension request?
- Under the regulation based on Article 19/A of Law No. 5549, there must be documents or serious indications supporting the suspicion, rather than mere suspicion, that the asset is related to the crime of money laundering or financing of terrorism.
- How is the report submitted?
- Application procedures and all submissions regarding suspicious transaction reports are carried out electronically through the MASAK.Online system.
- Can the institution's own internal reports be generated from the same data?
- Yes. Report definitions are made without code, and the results are saved and repeatable: where each figure originated from in terms of cases and events remains traceable.
- Can you find which rule generated a report from a year ago?
- Yes. Which version of which rule triggered the event is recorded alongside the event.