Common red flags that could trigger SAR reporting (2024)

21 FEB 2023

Suspicious activity reporting (SAR) is a critical component of anti-money laundering (AML) compliance that requires reporting entities to report any suspicious or potentially illegal activity to the relevant authorities.

Common red flags that could trigger SAR reporting (1)

SAR reporting helps to detect money laundering and other financial crimes and ensures reporting entities remain compliant with regulatory requirements. The agency responsible for overseeing SAR reporting in New Zealand is the Financial Intelligence Unit (FIU).

SAR reporting is usually triggered by a red flag, which is a warning sign that potentially may indicate suspicious activity. Reporting entities must remain vigilant and monitor their customers' activities for any red flags that could indicate illicit behavior.

There are several red flags you should be on the lookout for when monitoring customer activities for potential suspicious activity. These red flags can vary based on the sector your business is part of and the nature of the customer relationship.

Common red flags include:

  • Unusual transactions: Transactions that are unusual for a customer's profile, such as a large cash deposit or withdrawal from an account that has not previously made such transactions.
  • Unexplained transactions: Transactions that lack a clear purpose or explanation, such as a transfer from an unknown third party with no apparent business relationship.
  • High-risk customers: Customers that operate in high-risk industries or have a history of criminal or terrorist activity.
  • Customer due diligence failures: Failure to collect sufficient customer due diligence information or failure to update that information regularly.
  • Multiple transactions: A series of transactions that are structured to avoid regulatory reporting requirements or to obscure the true nature of the transactions.
  • Geographical risks: Transactions that involve high-risk countries or jurisdictions, or countries that are subject to international sanctions.
  • Political exposure: Transactions that involve politically exposed persons (PEPs) or their family members.
  • Suspicious behavior: Unusual customer behavior that cannot be easily explained, such as frequent and unusual transactions, or unusual requests for confidentiality.

Effective AML programs must include robust customer due diligence procedures, monitoring and reporting systems, and staff training. By staying alert and identifying potential red flags, reporting entities can contribute to the fight against money laundering and terrorist financing protecting the integrity of the financial system.

Give our team a call today with any questions – we are here to help.

Common red flags that could trigger SAR reporting (2024)

FAQs

Which of the following are red flags that may trigger filing a SAR? ›

Common red flags include: Unusual transactions: Transactions that are unusual for a customer's profile, such as a large cash deposit or withdrawal from an account that has not previously made such transactions.

What would trigger a SAR investigation? ›

Suspicious Activity Reports (SARs) are crucial documents filed by financial institutions to report potentially illicit activities. Triggers for filing SARs include unusual transactions, patterns, or behaviors that raise suspicions of money laundering, fraud, or terrorist financing.

What are the red flag indicators for suspicious transactions? ›

Frequent cross-border flow of transactions, especially with high-risk countries. A large amount of cash deposited in smaller portions. A large amount of cash deposited in an account at once. Payment received in account, not matched with goods shipped or trade-based money laundering.

What is a common reason to file a SAR report? ›

The purpose of the Suspicious Activity Report (SAR) is to report known or suspected violations of law or suspicious activity observed by financial institutions subject to the regulations of the Bank Secrecy Act (BSA).

What are red flags and triggers? ›

A trigger is an event, sound, sight, smell, or touch, that elicits an emotional response or prompts the memory of a trauma or unpleasant event. A red flag is a warning sign of danger ahead.

What are the 10 red flag symptoms? ›

Examples of red-flag symptoms in the older adult include but are not limited to pain following a fall or other trauma, fever, sudden unexplained weight loss, acute onset of severe pain, new-onset weakness or sensory loss, loss of bowel or bladder function, jaw claudication, new headaches, bone pain in a patient with a ...

What are two triggers for a suspicious activity report SAR? ›

If potential money laundering or violations of the BSA are detected, a report is required. Computer hacking and customers operating an unlicensed money services business also trigger an action. Once potential criminal activity is detected, the SAR must be filed within 30 days.

What are examples of suspicious activity? ›

Leaving packages, bags or other items behind. Exhibiting unusual mental or physical symptoms. Unusual noises like screaming, yelling, gunshots or glass breaking. Individuals in a heated argument, yelling or cursing at each other.

What are the red flags for transactions? ›

In Anti-Money Laundering (AML) compliance, a red flag describes a warning sign that indicates the possibility of money laundering or other criminal activity. Red flags can include transactions involving companies in sanctioned jurisdictions, large volumes, or funds being transmitted from unknown or opaque sources.

What is the red flag report? ›

A red flag report is an important document for construction, engineering and commercial property projects that outlines major risks or issues needing attention. Red flag reports allow project managers to identify problems early before they become crises.

Which is an example of a red flag about the transaction? ›

Other actions that are considered AML red flags in terms of suspicious transactions include large cash payments, unexplained third-party transactions, the use of multiple accounts, or the use of foreign bank accounts or virtual wallets, especially if they originate from diverse jurisdictions.

In what situation would a SAR be filed? ›

SAR Report must be filed when a financial institution or individual suspects a customer is involved in suspicious or potentially criminal activities, such as money laundering, terrorism financing, or other illegal activities.

Who typically determines when a SAR needs to be filed? ›

A bank should assess all of the information it knows about its customer, including the receipt of a law enforcement inquiry, in accordance with its risk-based BSA/AML compliance program. The bank should determine whether a SAR should be filed based on all customer information available.

What line of defense is responsible for filing a suspicious activity report (SAR)? ›

The AML officer should be the contact point for all AML issues for internal and external authorities and be responsible for reporting suspicious transactions. Members of the second line of defense must have sufficient independence from the business lines to prevent conflicts of interest.

Under which of the following circ*mstances would you file a SAR? ›

In the United States, financial institutions must file a SAR if they suspect that an employee or customer has engaged in insider trading activity. A SAR is also required if a financial institution detects evidence of computer hacking or of a consumer operating an unlicensed money services business.

Which of the following is a red flag for money laundering? ›

Large transactions, structuring, layering property transactions, the use of anonymous entities, and unexplained wealth increases are five common AML red flags for money laundering.

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