Suspicious transaction reporting: when, how, and what follows

One question unsettles businesses more than any other in compliance: when do we report? The prevailing fear is reporting wrongly and damaging a customer relationship. But the standard is not certainty — it is reasonable suspicion you have not been able to explain away.

What creates the obligation

The obligation arises where there are reasonable grounds to suspect that funds are proceeds of crime, or connected to terrorist financing, or that a customer is concealing the true beneficial owner or the source of funds. The transaction need not have completed: an attempted transaction that was abandoned is reported just as a completed one is.

Indicators we meet in practice

• A customer who refuses or stalls on beneficial ownership information with no intelligible reason
• Transactions structured just under a regulatory threshold without reaching it
• Amounts out of proportion to the customer's stated activity or apparent means
• Unusual insistence on speed, or on cash, with no commercial rationale
• Payment by a third party with no evident connection to the transaction
• A sudden cancellation after you ask about the source of funds

How it is filed

Reports are filed through the goAML system to the Financial Intelligence Unit — not to the supervisory authority, not to the police, and not by email. That presumes your business is already registered on the system with an active user — registering at the moment you need to report is far too late.

Do not tip off the customer

Disclosing that a report has been made, to the customer or to any unauthorised party, is prohibited and is a breach separate from the subject of the report. The prohibition covers indirect signalling too: an abrupt change in how you deal with them, requesting documents in a tone that reveals why, or advising them to withdraw the transaction. Continue the relationship as it was unless instructed otherwise.

And after submission?

Do not expect a reply or confirmation of an outcome. Silence is neither neglect nor exoneration. Your obligation does not end at submission: you retain a copy of the report and everything it rested on, you continue to monitor the relationship, and you file a supplementary report if something new emerges. Whether to continue dealing is a commercial decision that remains yours — unless instructions arrive that constrain it.

Readiness before the need

• Register on goAML now, not at the first suspicion
• Name who files and who covers for them in their absence
• Write the internal escalation path: who is told first, and within what time
• Train the front line on the indicators — they see them before anyone else
• Keep a record of every case examined and not reported; an examination with no trace may as well not have happened