Suspicious Activity Reporting (SARs/STRs)

The direct escalation if an alert is confirmed suspicious.

As soon as a suspicious transaction arises in normal day-to-day monitoring.

If you see suspicious activity from a pre-onboarding prospective client. However, often SAR/STR frameworks assume an established or attempted relationship.

Immediately file suspicious activity reports when multiple third-party deposits or rapid pass-through transactions indicate money mule usage. Include details of account interconnections, deposit patterns, and beneficiary relationships to facilitate further investigation into the flow of illicit funds.

Require immediate internal escalation and formal reporting whenever transaction monitoring or frontline staff notice indicators of structured small-value transfers designed to avoid thresholds. SARs/STRs should explicitly describe the pattern, such as multiple IDs, convergence to a single recipient, or inconsistency in sender details, and highlight the layering tactic used to conceal illicit proceeds.

Leverage specialized blockchain analytics to detect wallet addresses known for privacy features or mixer-first funding patterns, focusing on anomalous deposits or withdrawals that suggest an attempt to mask fund origins. When activity is flagged, compliance teams rapidly investigate and file SARs detailing the anonymization methods employed, ensuring regulatory bodies are informed of potential layering or advanced obfuscation tactics.

• Promptly file SARs/STRs when identifying accounts receiving payments labeled as "forced donations" or featuring coercion terminology in transaction narratives.
• Escalate any abrupt spikes in deposits linked to publicly known extortion events or recognized criminal groups for further regulatory investigation.

File SARs/STRs immediately when observing transaction behaviors tied to migrant smuggling, such as frequent bribe-related payments to transportation or border personnel, repeated deposits matching typical smuggling fee levels, or mentions of fraudulent immigration documents in wire narratives. This ensures timely regulatory escalation of human smuggling-specific red flags.

File reports when material discrepancies arise in bill of exchange documentation, such as unexplained over-invoicing or multiple phantom shipments. Include indicators of collusive behavior, layering of funds through multiple jurisdictions, or beneficial ownership concealment to assist authorities in investigating suspected Bill of Exchange Fraud networks.

File SARs/STRs upon detecting multiple counterfeit notes from a specific customer or a sustained pattern of suspect cash deposits. Even if local law treats passing counterfeit currency purely as a criminal offense, financial institutions must still escalate it as suspicious from an AML perspective. Consistent reporting safeguards the banking system by alerting authorities to potential large-scale distribution operations that blend counterfeit with legitimate cash deposits.

Promptly file detailed SARs/STRs whenever blockchain monitoring or other analytics identify transactions tied to known Darknet market addresses, repeated use of mixing/tumbling services, or unexplained cross-chain bridging that conceals fund flows. Include relevant wallet addresses, transaction patterns, and potential links to illicit marketplaces in reports for law enforcement scrutiny.

File SARs/STRs promptly for gambling-specific red flags, including:

• Large or structured chip buy-ins followed by minimal betting and quick redemption
• Forged receipts showing inflated winnings
• Staff collusion enabling chip-dumping schemes

File timely SARs/STRs whenever staff observe repeated high-value chip purchases or redemptions with minimal play, attempts to cash forged TITO tickets, or bulk chip passing among multiple patrons without legitimate gaming rationale. Detailed reporting helps authorities investigate potential chip-based laundering schemes.

Require prompt SAR filing whenever customers claim frequent high-value winnings from unregulated gambling rings, submit questionable tickets purchased from genuine bettors, or show improbable win-loss ratios designed to mask illicit proceeds. This direct escalation measure confronts the technique’s reliance on minimal documentation and anonymous venues, ensuring authorities are alerted to potential underground gambling-based laundering.

File SARs when identifying repeated deposit refunds without legitimate, documented rationale, or when auction items are flipped at inflated or below-market prices in rapid succession. Detailed reports should highlight any hidden beneficial ownership structures, shell entities, or cyclical transactions that strongly indicate layering or integration within auction processes.

Require prompt SAR filing when discovering repeated or near-identical check submissions across multiple accounts, physically altered checks, or mismatches in endorsements via RDC. Provide detailed deposit timelines, account connections, and check images to authorities for a thorough investigation.

Promptly file SARs/STRs when large lump-sum deposits lack credible investment rationale, or if repeated cross-border sub-account reinvestments appear designed to conceal beneficial ownership or the illicit origins of funds. Document all relevant evidence, including discrepancies in ownership records or refusals to provide detailed source-of-funds information, to aid further investigation by authorities.

Implement specialized internal triggers for transactions that suggest sanctions evasion, such as the sudden rerouting of funds to a newly established shell company with ties to sanctioned regions. Promptly submit SARs/STRs to relevant authorities. This explicit focus on sanctions evasion scenarios ensures that these red flags receive the highest-priority investigation and reporting.

Establish clear escalation protocols for subsidy-related red flags. Promptly file SARs when farmland or livestock data conflicts with official registries, or when financial flows suggest double-funded grant schemes, undeclared paramilitary beneficiaries, or other fraudulent manipulations of agricultural subsidies.

File SARs/STRs when accounts receive repeated "lottery fee" or "prize tax" deposits from unrelated individuals without legitimate context, or exhibit other indicators of advanced fee fraud. Explicitly document references suggesting fraudulent lotteries and escalate quickly to relevant authorities for investigation.

Promptly file regulatory reports upon detecting a cycle of new deposits used to pay off earlier investors, in the absence of verifiable profit generation. Include details of unusual layering through multiple shell entities, abrupt capital inflows that contradict disclosed business activities, and the repeated use of investor recruitment as the primary revenue source.