The reporting deadlines start once you have formed your suspicion, which may be at any time in your business relationship. A suspicion is only ‘formed’ after the appropriate person in your business or organisation has conducted proper checks and determined that there are reasonable grounds for suspicion.

For example, an employee who doubts that a customer is who they claim to be should tell their supervisor, who should alert the AML/CTF compliance officer. The reporting time frame only starts once the compliance officer has finished their own investigation and has formed a suspicion on ‘reasonable grounds.

This period must not be longer than 15 (fifteen) days, excluding Saturdays, Sundays, and Public Holidays, after a person became aware of the facts which give rise to suspicion.