What is a Suspicious Transaction or Activity Report?
A report made by a financial institution about suspicious or potentially suspicious activity. The criteria to decide when a report must be made varies from country to country but generally is any financial transaction that does not make sense to the financial institution, is unusual for that particular client or appears to be done only for the purpose of hiding or obfuscating a transaction.
How can I detect a suspicious transaction or activity?
Generally, you should pay attention to all transactions or activities that are inconsistent with the known profile of the customer.
Here is a non-exhaustive list of some indicators.
- The customer is reluctant to provide details of their identity.
- A cash transaction is unusually large.
- The customer requests currency in large denomination notes.
- Non-disclosure of the source of funds by the customer.
- Dubious explanations as to the source of funds.
- Structuring of transactions.
Reporting a suspicious transaction or activity
If your organization is subject to the requirements of the Money Laundering (Prevention) Act No. 8 of 2011 and Suppression of Financing of Terrorism Act No. 9 of 2011, you must take steps to identify any activity you suspect may be linked to money laundering or terrorist financing. If you know or suspect there is such a link you must report it to the Financial Intelligence Unit (FIU).
When to report
A financial institution or person carrying on a scheduled business (i.e. relevant business or designated non-financial business and profession (DNFBP) is required to pay attention to –
- all complex, unusual or large business transactions, whether completed or not;
- all unusual patterns of transactions, whether completed or not;
- insignificant but periodic transactions, that have no apparent or visible economic or lawful purpose;
- electronic funds transfers that do not contain complete originator information;
- relations and transactions with persons, including business and other financial institutions, from countries that have not adopted comprehensive anti-money laundering legislation.
Where a financial institution or person carrying on a scheduled business suspects or has reasonable grounds to suspect that a transaction, proposed transaction or attempted transaction, is related to a money laundering offence or that the funds or property are the proceeds of crime, it shall promptly report the transaction to the Unit in a form approved by the Director of the Unit.
How to submit a Suspicious Activity Report
Your Compliance Officer can file a report with the FIU manually by downloading a copy of the STR form from the FIU’s website or requesting a copy from the FIU directly, which can be sent to them via e-mail.
The completed STR can be sent by courier to the:
Financial Intelligence Unit
Corner of Turkey & Independence Street
Commonwealth of Dominica
File the STR with the FIU electronically via e-Filing