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A suspicious activity or transaction is one that potentially involves abuse or misuse of the financial system to commit a criminal offence. Often the criminal offence in question relates to money laundering, terrorist financing or proliferation financing. Guidance as to the type of activities or transactions which could be considered suspicious could be found at Schedule 3 of the AMLTF Code, 2008 or in the Guidance Note on Suspicious Transaction Reports or Schedule of the AML Code.
A suspicious activity report (“SAR”), sometimes referred to as a suspicious transaction report (“STR”), is a document detailing alleged suspicious activities or transactions.
Absolutely any individual or entity aware of suspicious activity or transaction is entitled to complete the SAR form and file a SAR. However, there are several instances where the law mandates individuals or entities to report suspicious activity in defined circumstances. Failure to do so amounts to a criminal offence which can lead to persons or entities being charged.