Suspicious transaction report

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Suspicious transaction report

STRAlso called suspicious matter report, suspicious activity report

Definition

A suspicious transaction report is a filing a regulated firm makes to its national financial intelligence unit when it suspects funds are the proceeds of crime or linked to terrorist financing. FATF standards require it in every member country. The UK and US call the equivalent filing a suspicious activity report.

ALERT RAISEDINVESTIGATIONMLRO DECISIONFIU FILING
Fig. 1 · Suspicious transaction report
FATF Recommendation 20 · AMLD4 Article 33 · AMLR Article 69
Key rulesFATF Recommendation 20 · AMLD4 Article 33 · AMLR Article 69
Applies toObliged entities in EU member states
RegionsGlobal · EU · APAC
01

How it works

Monitoring alerts, staff referrals and screening hits reach investigators, who review the customer's profile and transaction history. If suspicion remains, the case goes to the money laundering reporting officer, who decides whether to file. The report describes the parties, transactions and grounds for suspicion and is submitted through the FIU's online system. Staff must not tip off the customer, and the firm keeps records of every decision.

STRs matter because they are the main route by which private-sector data reaches law enforcement. FIUs analyse reports, link them to other intelligence and pass cases to police and tax authorities. Supervisors test whether firms report promptly and to a good standard. Failure to report, late filing and defensive over-reporting all draw criticism in AML inspections.

Step 1DetectAlerts, referrals and screening hits flag unusual activity.
Step 2InvestigateReview customer profile, transactions and available information.
Step 3DecideThe reporting officer decides whether suspicion is met.
Step 4FileSubmit the report to the FIU without tipping off.
Step 5RecordKeep the decision rationale and supporting evidence.
02

The rules

Global · February 2012, regularly updatedFATF Recommendation 20FATF Recommendations, Recommendation 20: Reporting of suspicious transactions

Requires firms that suspect funds are criminal proceeds or linked to terrorist financing to report promptly to the financial intelligence unit.

Financial institutions and designated non-financial businesses in FATF jurisdictions
EU · 26 June 2017AMLD4 Article 33Directive (EU) 2015/849 on the prevention of the use of the financial system for money laundering or terrorist financing

Requires obliged entities to report suspicious transactions to the FIU promptly and respond to its requests, through national transposing laws.

Obliged entities in EU member states
EU · Applies from 10 July 2027AMLR Article 69Regulation (EU) 2024/1624 on the prevention of the use of the financial system for money laundering or terrorist financing

Sets a directly applicable duty to report suspicions to the FIU regardless of amount, with a common reporting format set by AMLA standards.

Obliged entities in the EU
03

Common questions

What is the difference between an STR and a SAR?

They serve the same purpose. STR is the FATF term and is used in the EU and many Asian and African countries. The UK and US use suspicious activity report, a term that also covers behaviour that is not a transaction.

Is there a minimum amount for filing an STR?

FATF standards set no threshold. Any suspicion must be reported regardless of size. Some countries apply thresholds to other reports, such as large cash transaction reports, but suspicion-based reporting has no minimum amount.

Can a customer find out about an STR?

No. Tipping-off rules make it an offence in most jurisdictions to tell a customer or third party that a report has been made or an investigation is under way. Firms train staff to handle customer questions without disclosure.

Who receives an STR?

The national financial intelligence unit. Examples include the FIUs of each EU member state, AUSTRAC in Australia and the Suspicious Transaction Reporting Office in Singapore. In the UK, SARs go to the UK Financial Intelligence Unit within the National Crime Agency.