Question 1

What is a Suspicious Matter Report (Australia)?

Accepted Answer

A report to AUSTRAC under section 41 of the AML/CTF Act lodged when a reporting entity forms a suspicion on reasonable grounds that information may be relevant to investigation of a possible offence, or that the customer is not who they claim to be, or that the matter relates to terrorism financi...

Question 2

What is a Suspicious Activity Report (United States)?

Accepted Answer

A SAR is filed with FinCEN by US financial institutions under 31 CFR Chapter X when a transaction (or attempted transaction) of at least USD 5,000 (USD 2,000 for MSBs) is suspected to involve funds from illegal activity, to be designed to evade BSA reporting, to have no apparent lawful business p...

Question 3

What is a Suspicious Transaction Report (rest of world)?

Accepted Answer

The generic FATF terminology used in most non-US, non-AU jurisdictions. The EU AMLR uses "reporting of suspicions" to the national FIU. The UK uses Suspicious Activity Reports filed with the NCA. Form, threshold and deadline vary; the underlying obligation — to report a suspicion to a national FI...

Question 4

What is "tipping off"?

Accepted Answer

Disclosing to the customer (or any third party) that a suspicious-matter report has been or will be made, or that an investigation is or may be under way. Tipping off is a criminal offence in every FATF-aligned jurisdiction. It is one of the most important constraints on customer-facing communica...

Question 5

What is a Threshold Transaction Report (Australia)?

Accepted Answer

A report under section 43 of the AML/CTF Act, lodged with AUSTRAC for any transfer of physical currency or e-currency of AUD 10,000 or more (or foreign currency equivalent). Filing deadline is 10 business days. Structuring (deliberately splitting transactions to fall below the threshold) is a sep...

Question 6

What is a Currency Transaction Report (United States)?

Accepted Answer

Filed with FinCEN under 31 CFR §1010.311 for any deposit, withdrawal, exchange or transfer of currency of more than USD 10,000 in a single business day by, through or to a financial institution. Filing deadline: 15 calendar days. As in Australia, structuring is itself a federal offence (31 USC §5...

Reporting obligations (SMR / SAR / STR)