When must a suspicious activity report be submitted?

When do I have to report suspected money laundering?

If there are facts that indicate money laundering or terrorist financing, this suspicion must be reported immediately. The threshold of suspicion is quickly reached. It is sufficient if the customer relationship appears unusual or conspicuous compared to other transactions. You do not need to know for certain that a criminal offence or other criminal activity has taken place.

A suspicious activity report must also be submitted if problems arise in connection with the beneficial owner or if the client does not fulfil his disclosure obligation in this regard.

Where do I have to report suspected money laundering or terrorist financing?

Suspicious activity reports must be submitted to the Financial Intelligence Unit (FIU) via the electronic reporting portal goAML.

What do I have to look out for after submitting a suspicious activity report?

The transaction may not be executed after a suspicious activity report has been submitted, unless such a postponement of the transaction would hinder the investigation of a criminal offence. The transaction may only be executed with the approval of the FIU or the public prosecutor's office or after the end of the third working day following the submission of the suspicious activity report, unless the FIU or the public prosecutor's office has prohibited the execution of the transaction.

Furthermore, neither the customer nor a third party may be informed. The potential offender should not be warned.