The requirement to report suspicious transactions states that banks, financial institutions, cash dealers or members of relevant professions shall make a report to the FIA on any transaction which they have reason to believe may be a suspicious transaction.

Where there is a business relationship, a suspicious transaction will often be one which is inconsistent with customer’s known, legitimate or personal activities or with the normal business for that type of account. Therefore, the first key to recognition is knowing enough about your customer and customers business to recognize that a transaction or series of transactions, are unusual. Reliance on what should be reported is therefore mainly on ones assessment based on knowledge and experience as well as specific circumstances of the transaction. The assessment should therefore be based on a reasonable evaluation of relevant factors including the knowledge of the clients business, financial history, background and behavior. Section 35 and 36 of the MLA therefore only provides indicators of suspicious transactions that might be useful in helping you assess whether a transaction is suspicious and should be reported.