FIC webinars on reporting unusual and suspicious transactions

Posted on by

The Financial Intelligence Centre (FIC) will host free webinars this week and in March on the reporting of unusual and suspicious transactions.

Each webinar is for one of the following four types of accountable institution: legal practitioners, trust and company service providers, estate agents, and high-value goods dealers.

Any business – not only accountable institutions as defined in Schedule 1 to the Financial Intelligence Centre Act (FICA) – is obliged to identify and report to the FIC unusual and suspicious transactions and activities potentially linked to money laundering or terrorist financing. This is line with section 29 of FICA and applies to anyone who carries on, oversees, or manages a business, or who is employed by a business.

A suspicious transaction report (STR) must be filed when the business knows or suspects it has received or is about to receive the proceeds of crime or that is related to terrorist activity. This includes when the business knows or suspects an activity or transaction:

  • may be relevant to the investigation of tax evasion or an attempt to evade a tax;
  • relates to the financing of terrorist and related activities;
  • contravenes the prohibition of providing finance to a sanctioned person under section 26B of FICA;
  • is structured with the intention of avoiding being reported in terms of FICA;
  • is linked to the proceeds of unlawful activity;
  • facilitates the transfer of the proceeds of unlawful activities; or
  • has no apparent business or lawful purpose.

The person filing the STR does not have to prove that the funds involved in the transaction are linked to a crime. The report can be based on a suspicion. No monetary limit or threshold applies to the filing of an STR.

The following factors may raise suspicions about a transaction:

  • The commissions or fees appear abnormally excessive.
  • The transaction does not appear to be in keeping with normal or usual industry practices.
  • The transaction seems to be unusually large or inconsistent with the client’s financial standing.
  • The client provides insufficient, vague, or suspect information about the transaction.

When a transaction has not taken place, but the client’s behaviour leads you to suspect that your entity may be abused for money laundering or terrorist financing, this must be reported in a suspicious or unusual activity report (SAR).

The dates and times of the webinars are:

Thursday, 29 February
10am to 11.30am: Legal practitioners
12pm to 1.30pm: Trust and company service providers

Thursday, 7 March
10am to 11.30am: High-value goods dealers
1pm to 2.30pm: Estate agents

Click here to register.

Each webinar will cover the following:

  • What is a suspicious and unusual transaction and activity report.
  • How to submit an STR or an SAR.
  • Sector-specific case studies and red flag indicators.
  • The timeframes for reporting and transaction monitoring.
  • Reporting using the FIC’s registration and report system, goAML.