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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.
The persons (both natural and legal) that can file a SAR are financial institutions (FIs), designated non-financial businesses and professions (DNFBPs), non-profit organisations (NPOs) and any other person, once the suspicion comes to their attention in the course of their business, trade, employment or profession.