REASONABLE GROUNDS FOR SUSPICION

You must submit a report if you have ‘reasonable grounds’ for suspicion. This means that after considering all the information and circumstances available, a reasonable person would conclude that an STR or SAR should be submitted. In the report you will be asked to explain what has made you suspicious.

If you or anyone in your business or organisation notices something unusual you must conduct enhanced due diligence checks to determine if you have reasonable grounds for your suspicion. Once the appropriate person in your business or organisation has completed the checks and ‘forms a suspicion,’ you must submit the SAR or STR within the required timeframe.

You or your staff, including your AML/CTF compliance officer don’t have to know exactly what criminal activity your customer might be involved in, or where the suspect funds or property came from, to make an STR.