You must not tell anyone other than the people within your organisation who have reporting responsibility and the FIC. that you have formed a suspicion about a customer or that you have submitted an STR, unless you have an official exemption. Revealing this information is an offence that’s punishable with imprisonment for a period up to 15 years or a fine up to R100 million.
Your other obligations when you submit an STR include:
- not revealing any information that might reasonably lead a person to conclude that you have formed a suspicion about them or have told the Centre (FIC) about that suspicion
- not revealing any request, the FIC or law enforcement agencies make for more information about an STR.
Once you form a suspicion about a customer, be discreet when seeking further details so they don’t realise you may make, or have already made, an STR. However, asking the customer for more information, including about their identity or the source or destination of their funds, is not considered ‘tipping off.’
You can’t give information about a specific STR to any external parties appointed to review your AML/CTF program, even if they are reviewing your STR obligations.