What Is a Suspicious Transaction Report (STR)?

• April 20, 2024
• Rachna Pandya

A suspicious transaction report (STR), also known as a suspicious activity report (SAR) in some jurisdictions, is a critical tool in the battle against money laundering and terrorist financing.

When discussing suspicious transaction reports (STRs) in the context of anti-money laundering (AML), it’s vital to understand what is a suspicious transaction report, suspicious transaction in money laundering, and how to identify suspicious transaction reports.  

At the same time, the article also throws light on who should file STR in AML, and the guidelines and expectations surrounding their submissions.

So, let’s begin this integral aspect of anti-money laundering exploration.

What Is a Suspicious Transaction Report?

An STR in AML is a comprehensive document that captures details about transactions that appear unusual or have no apparent lawful purpose. 

A detailed record that is submitted to the relevant authority, such as a Financial Intelligence Unit (FIU), when a financial institution or entity suspects a transaction may be connected to money laundering, terrorist financing, or other criminal activities. It includes the reporting entity’s information, the specifics of the transaction (such as date, amount, and parties involved), and a narrative explaining why the transaction is deemed suspicious. 

Organizations required to file STRs include a wide array of financial entities, such as –

• banks,
• money services businesses,
• and casinos,
• among others.

As of 2024, this will expand to include businesses that –

• transport currency,
• and mortgage administrators,
• brokers,
• and lenders​​.

Suspicious Transaction in Money Laundering

So, what is a suspicious transaction report in money laundering? In the context of money laundering, suspicious transactions are typically those that don’t match the customer’s profile or usual business activities.

They may involve –

• large transactions,
• rapid movement of funds,
• or other factors that raise concerns,

based on the customer’s known financial history or behavior.

A risk-based approach, including customer due diligence and continuous transaction monitoring, is essential for identifying these transactions​​.

How Do Suspicious Transactions Fit into The Money Laundering Steps?

Now, to understand how suspicious transactions fit into the money laundering steps, let’s delve into the three classic stages of money laundering: placement, layering, and integration.

STR in AML – Placement, Layering & Integration Techniques

Image Caption: A flowchart illustrating the detection of suspicious transactions in money laundering through the stages of placement, layering, and integration.

1. Placement is the initial stage where the illicit funds are introduced into the financial system.

This could be through –

• bank deposits,
• purchases of high-value items,
• or the use of cash-intensive businesses,
• like casinos or car washes.

How To Identify Suspicious Transaction Report (STR) In The Placement Stage

In this stage, the money is still close to its criminal origins, and transactions here could easily raise suspicion and lead to the filing of an STR​. 

2. Layering is the second stage, where the launderer conducts a series of transactions to distance the money from its source.

This complex web of transactions makes it difficult to trace the money back to the criminal activity. –

• Financial products,
• electronic transfers,
• and even cryptocurrency trades,

are used to confuse the trail.

How To Identify Suspicious Transaction Report (STR) In The Layering Stage

Suspicious transactions can be identified at this stage too, as launderers may move funds rapidly between accounts or change the money’s form through investments​. 

3. Finally, integration is where laundered money is reintegrated into the legitimate economy.

This can be through –

• real estate purchases,
• luxury goods,
• or business investments.

How To Identify Suspicious Transaction Report (STR) In The Integration Stage

At this point, the money appears legitimate, and identifying suspicious activity can be more challenging. However, significant and unusual transactions from accounts that previously exhibited suspicious activity during the layering stage could be red flags and thus included in an STR​. 

The role of STRs is critical in each of these stages. Financial institutions monitor for indicators of money laundering at each step and file STRs when they detect activities that could suggest an attempt to introduce, disguise, or integrate illicit funds.

How To Identify Suspicious Transactions Report (STR) Red Flags

To identify whether a transaction should be reported, entities rely on “reasonable grounds to suspect” (RGS), which refers to a situation where there is a possibility of money laundering or terrorist financing offense.

It is a lower threshold than having to confirm an offense and is based on facts, context, and ML/TF indicators provided by regulatory bodies such as FATF (which we’ll speak about momentarily).

How Do Criminals Exploit Threshold Limits to Avert STR Red Flags?

Exploiting threshold limits to avert STR red flags is a sophisticated technique that financial criminals use to launder money. It involves –

• Structuring and smurfing: Staying under the radar of regulatory reporting requirements by making multiple small transactions instead of large ones and,
• Complex money trail: Using complex networks of accounts and transactions to hide the origins of illicit funds.

Image Caption: Diagram depicting how to identify suspicious transaction report indicators, including structuring, smurfing, and complexifying money trail techniques used to evade detection.

Let’s throw light on each one of these tactics exploited by the miscreants. –

1. Structuring

Definition: One common method is “structuring”, where large amounts of money are broken down into smaller transactions to stay below thresholds that would trigger mandatory reporting to financial authorities. These smaller transactions are often distributed across multiple accounts or even across different institutions to further complicate the money trail​​.

Objective: Criminals use various tactics to evade the red flags that could lead to the filing of a suspicious transaction report (STR).

2. Smurfing

Definition: “Smurfing” is a specific type of structuring where individuals, referred to as smurfs, are used to make these small transactions. The term is derived from the multiple, small-scale operations that collectively accomplish a larger goal without attracting undue attention​​.

Objective: By doing so, smurfs help launderers to deposit illicit funds incrementally, thereby escaping the attention of regulatory bodies and concealing the origin of the funds.

A Situation Example:

• Context: A person acquires a large sum of illegal money.
• Action: Instead of depositing this sum into one account, they break it down into multiple deposits just under $10,000 each—a threshold that often triggers mandatory scrutiny in many jurisdictions.
• Distribution: These smaller sums are deposited into various accounts, potentially at different banks or on different days, to prevent any single transaction from appearing suspicious.

3. Adding Complexity to the Money Trail

Techniques Used:

• Rapid transfers between accounts.
• Conversion into different currencies.
• Utilization in gambling activities, later withdrawn as “winnings”.

Objective: These actions are common during the layering stage of money laundering and are designed to obfuscate the money trail and add layers of complexity.

How Do Financial Institutions Identify Suspicious Transactions Reports (STR)? (In 7 Steps)

Financial institutions and regulators work tirelessly to detect and prevent suspicious transaction in money laundering. The following are the salient aspects of STR in AML in the financial crime genre.

1. Employing Advanced Technology

AI and machine learning are at the forefront of technology employed to combat money laundering and terrorist financing. These technologies help adapt to ever-evolving criminal tactics, enhancing the ability to detect suspicious activities efficiently.

2. Setting AML Transaction Monitoring Thresholds

Financial institutions implement sophisticated algorithms and models to monitor transactions that may indicate illicit activities. They use these thresholds to detect suspicious behavior based on customer risk profiles, transaction patterns, and other relevant factors.

3. Calibrating Thresholds

Balancing the sensitivity of the monitoring system to identify real threats while minimizing false positives accurately. Proper calibration is crucial as false positives can be costly and time-consuming, diverting resources from genuine threats.

4. Continual Refinement Of Monitoring Systems

To keep up with new criminal methodologies and changes in the regulatory environment. Ongoing adjustments and updates to monitoring strategies and tools ensure that financial institutions stay one step ahead of criminals.

5. Regulatory Requirements

Compliance with laws and regulations is fundamental. Financial institutions must adhere to national and international financial regulatory frameworks, which dictate specific reporting obligations and standards.

6. Human Intervention And Expert Analysis

While automated systems play a crucial role, human oversight is essential. Analysts review and investigate alerts generated by automated systems, applying their expertise to distinguish between false positives and actual suspicious activities.

7. Collaboration And Information Sharing

Institutions often collaborate with each other and with government bodies to share information about potential threats and fraudulent patterns. This collective effort helps in creating a more robust defense against money laundering activities.

How does FATF Identify STR In Its Recommendation?

The Financial Action Task Force (FATF) has established Recommendation 20 to detail the requirements for reporting suspicious transactions. It compels obligated financial and non-financial institutions, and concerned citizens alike to alert their Financial Intelligence Unit (FIU) when they suspect activities may be linked to criminal or terrorist activities.

• Key requirement – “reasonable grounds to suspect” (RGS): Central to this recommendation is the concept of “reasonable grounds to suspect”. This highlights that the need to report is based on suspicion supported by contextual clues and risk indicators, rather than the certainty of illegal activities.

• All-inclusive reporting obligations: According to FATF, all suspicious transactions, no matter the amount or whether completed or only attempted, must be reported. This rule underscores a proactive approach to tracking and mitigating financial crimes.

• Criminal scope beyond terrorism financing: The recommendation addresses not only the financing of terrorism but also all criminal acts that could serve as predicate offenses for money laundering. Nations are urged to tailor these guidelines to their own legal and operational environments while adhering to the universal standards set by FATF.

Final Thoughts On Suspicious Transaction In Money Laundering

As international benchmarks for anti-money laundering and counter-terrorism financing, STR filings play a key role in preserving the integrity of the global financial system and thwarting financial abuse by criminals and terrorists.

Suspicious Transaction In Money Laundering – Salient Aspects (Recap)

• Accuracy and completeness in reporting: It is essential for reporting entities to provide complete and accurate information when filing STRs.
• Detailed monitoring and record-keeping: Detailed subject profiles should be created, transactions must be effectively monitored, and comprehensive records maintained as required by regulations.
• Effective compliance programs: Compliance programs should effectively identify and report suspicious activities.
• Clarity in communication: Reports should be written in clear, simple, and concise language to improve clarity and comprehension.
• Importance of STR quality: The quality of STRs is important for effective analysis and any potential investigations that follow.

Now that you are decently aware of what is a suspicious transaction report, for further insights on suspicious transaction in money laundering, STR in AML, or to discuss the optimal AML solutions for your enterprise, please connect with ThePerfectMerchant.

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Top FAQs On What Is A Suspicious Transaction Report

What triggers suspicious activity reports?
Triggers include transactions that are inconsistent with a customer’s known and legitimate business, involve large amounts of cash, or appear to be structured to avoid regulatory reporting.

What is a typical suspicious transaction report amount threshold?
This can vary by country, but common thresholds are transactions involving $10,000 or more in the U.S. or equivalent amounts in other currencies.

Who is responsible for reporting suspicious and unusual transactions?
Financial institutions, such as banks, credit unions, and money services businesses, are typically responsible for reporting suspicious transactions.

Within how many days should a suspicious transaction report ideally be submitted?
A suspicious transaction report should ideally be submitted within 30 days of detecting the suspicious activity.

How many types of suspicious transaction reports are there?
Generally, there are two main types: one for suspected money laundering and another for suspected financing of terrorism.

To whom is a suspicious transaction report submitted?
Suspicious transaction reports are usually submitted to the nation’s Financial Intelligence Unit (FIU) or a designated regulatory authority.

What is a suspicious transaction report example?
An example could be a report of multiple cash deposits just below the reporting threshold made repeatedly by the same individual across different branches.