Suspicious activity report

In financial regulation, a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) is a report made by a financial institution about suspicious or potentially suspicious activity as required under laws designed to counter money laundering, financing of terrorism and other financial crimes. The criteria to decide when a report must be made varies from country to country, but generally is any financial transaction that either a) does not make sense to the financial institution; b) is unusual for that particular client; or c) appears to be done only for the purpose of hiding or obfuscating another, separate transaction. The report is filed with that country's Financial Intelligence Unit, which is typically a specialist agency designed to collect and analyse transactions and then report these to relevant law enforcement teams.

Front line staff in the financial institution have the responsibility to identify transactions that may be suspicious and these are reported to a designated person that is responsible for reporting the suspicious transaction. This means that the front line staff can ask questions and in some cases refuse the transaction. However the financial institution is not allowed to inform the client or parties involved in the transaction that a SAR has been lodged, otherwise known as tipping off under the Financial Action Task Force's Recommendations.^[1]

The Financial Action Task Force's Recommendations are widely recognized as the international standard in anti-money laundering and countering financing terrorism with endorsements from 180 nations.^[2] FATF Recommendations set forth essential measures to combat money laundering and to protect domestic and international monetary systems including the application of preventive measures for the financial sector and other designated sectors; and establishment of powers and responsibilities for the relevant competent authorities (e.g., investigative, law enforcement and supervisory authorities), including guidelines regarding suspicious activity reports.^[3]

Most countries have laws that require financial institutions to report suspicious transactions and will have a designated agency to receive them. The agency to which a report is required to be filed for a given country is typically part of the law enforcement or financial regulatory department of that country. For example, in the United States, suspicious transaction reports^[4] must be reported to the Financial Crimes Enforcement Network (FinCEN), an agency of the United States Department of the Treasury. FinCEN maintains a team of analysts who meticulously review these Suspicious Activity Reports to detect potential money laundering activities. They also supply informational support to local law enforcement, along with national and international bodies including the International Association of Chiefs of Police (IACP), the National White-Collar Crime Center (NWCCC), and the National Association of Attorneys General (NAAG), facilitating further actions.^[5]

In Australia the Suspicious Matter Report must be reported to Australian Transaction Reports and Analysis Centre (AUSTRAC), an Australian government agency. A 2020 Bank Policy Institute study found that American SARs elicited a response from law enforcement in a median of 4% of reports, and that a tiny subset of those responses resulted in arrest and conviction, suggesting that 90% to 95% of SARs reports were false positives of unlawful activity.^[6]