We have noticed there is confusion in the market around when it is appropriate to file a SAR. A common question we are often asked is what ‘level’ of suspicion should we have before submitting a SAR.
The Financial Intelligence Unit (FIU) has developed guidelines to assist reporting entities. They suggest it’s good to have ‘facts and observations’ and ‘reasonable grounds for the submission’.
Our view is, if something does not feel right (gut feel), then act on your intuition. It may be that you will ask for more information, and if all the pieces don’t ‘fit’, or the customer is not forthcoming with the information, then submit a SAR. It will probably also help you to sleep better – erring on the side of caution is better than taking a “no care” approach.
Here’s the link if you would like more information:
If you are interested in learning more, or want to get your staff together for a learning session, we offer training which is personalised to your business. Contact us to discuss.