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Suspicious Activity Reports

Reporting a Suspicious Transaction or Activity

If your organisation is subject to the requirements of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (the Code) you must take steps to identify any activity you suspect may be linked to money laundering or terrorist financing. If you know or suspect there is such a link, you must report it to the Financial Investigation Agency (FIA).

The information below will help you decide whether you need to report a transaction or activity and how to go about doing so.

What Is a Suspicious Transaction Or Activity?

Even if you don’t have proof that a transaction or activity is linked to money laundering or terrorist financing, something about it may make you suspicious.

There are many different reasons why you or one of your employees might become suspicious about a transaction or activity. Often it’s just because it’s something unusual for your business – perhaps a customer has tried to make exceptionally large cash payment. Maybe the customer behaved strangely, or made unusual requests that didn’t seem to make sense. Perhaps the transaction they wanted to make just didn’t add up commercially.

You must look carefully at all unusual transactions to see if there’s anything suspicious about them.

Here are some indicators that a transaction could be suspicious (please note this is not an exhaustive list):

  • New customers and occasional or ‘one-off’ transactions
    • Checking identity is proving difficult.
    • The customer is reluctant to provide details of their identity.
    • There is no genuine reason for the customer using the services of a High Value Dealer.
    • A cash transaction is unusually large.
    • The cash is in used notes and/or small denominations.
    • The customer requests currency in large denomination notes.
    • The customer will not disclose the source of cash.
    • The explanation for the business and/or the amounts involved are not credible.
    • A series of transactions are structured just below the regulatory threshold for due diligence identity checks.
    • The customer has made an unusual request for collection or delivery.
    • Transactions having no apparent purpose or which make no obvious financial sense, or which seem to involve unnecessary complexity.
    • Unnecessary routing of funds through third-parties.
  • Regular and established customers
    • The transaction is different from the normal business of the customer.
    • The size or frequency of the transaction is not consistent with the normal activities of the customer.
    • The pattern of transactions has changed since the business relationship was established.
    • Sudden increases in the frequency/value of transactions of a particular customer without reasonable explanation.
  • Examples where customer identification issues have potential to indicate suspicious activity
    • The customer refuses or appears reluctant to provide information requested.
    • There appears to be inconsistencies in the information provided by the customer.
    • The customer’s area of residence is inconsistent with other profile details such as employment.
    • An address appears vague or unusual.
    • The supporting documentation does not add validity to the other information provided by the customer.
    • The customer is in a hurry to rush a transaction through, with promises to provide the information later.
  • Examples of activity that might suggest to staff that there could be potential terrorist activity
    • The customer is unable to satisfactorily explain the source of income.
    • Frequent address changes.
    • Media reports on suspected or arrested terrorists or groups

Reporting a Suspicious Transaction or Activity

As soon as someone in your organisation becomes aware of a suspicious transaction or activity they must report it to the ‘money laundering reporting officer’. It’s the money laundering reporting officer’s responsibility to decide whether they need to send a report or ‘disclosure’ about the incident to the FIA. They do this by making a Suspicious Activity Report.

If the money laundering reporting officer suspects money laundering or terrorist financing they must normally suspend the transaction and make a Suspicious Activity Report. But if it’s not practical – or not safe – to suspend the transaction, they should make the report as soon as possible after the transaction is completed.

The FIA receives and analyses Suspicious Activity Reports, and uses them to identify the proceeds of crime. It counters money laundering and terrorism by passing on important information to law enforcement agencies so they can take action.

The information below will help you decide whether you need to report a transaction or activity and how to go about doing so.

Reporting a Suspicious Transaction or Activity

Your money laundering reporting officer can send a Suspicious Activity Report to the FIA:

  • Electronically to reportingauthority@bvifia.org
  • by fax to 284-494-1435
  • by courier to the Financial Investigation Agency, 2nd Floor, LM Business Centre, Road Town, Tortola

Please note that any documentation that supports a SAR should be included with the SAR submission.

Contact Us

If you have any questions, feel free to contact us.

Address :

PO Box 4090
Road Town, Tortola VG1110
BRITISH VIRGIN ISLANDS

Phone : (284) 494-1335

Fax: (284) 494-1435

Email : info@fiabvi.vg

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