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What is a suspicious transaction?
Suspicious transactions are financial transactions in which there are reasonable grounds to suspect the transactions are related to the proceeds of criminal conduct as defined in the PCL. While the types of transactions, which may be used by a money launderer, are almost unlimited, a suspicious transaction will often be one, which is inconsistent with a customer’s known, legitimate business or personal activities or with the normal business for that type of facility. Therefore, the first key to recognition is knowing enough about the customer’s business to recognise that a transaction, or series of transactions, is unusual.
What is Money Laundering?

Money Laundering is the process used to conceal the true origin and ownership derived from the proceeds of criminal activities (predicate offence). There are three stages in the money laundering process:

1.  Placement involves inserting the proceeds derived from illegal activity into the financial system. This stage may involve cash deposits into a bank account at a financial institution.

2.  Layering involves attempting to camouflage the source of funds, audit trail and ownership of funds by creating complex layers of financial transactions. This stage may involve transactions such as purchasing securities, bitcoin, commodities and property with the funds deposited in the placement stage.

3.  Integration involves integrating the laundered proceeds back into the economy to provide the perception that the funds derive from legitimate activities. This stage may involve transactions such as selling securities, to provide the perception that the funds derived from investing in the stock market.

What is Terrorist Financing?
Terrorist Financing is the process of acquiring funds, goods or assets and other resources by legal or illegal means. The funds, goods or services could be aggregated in order to accumulate cash or physical resources. The funds or resources would be used to assist or encourage in the planning of terrorism acts. The funds are used to facilitate or implement terrorist activities. The end goal of individuals conducting Terrorist Financing is the conducting terrorist activities, the funds and resources are simply acquired to achieve the activity.

What is a Suspicious Activity Report?
Suspicious Activity Reports (SARs) are the FRAs most important source of information. Many individuals launder money to conceal illegal activity, such as drug trafficking, fraud, illegal firearms sales, and even terrorism. It fuels criminal conduct, allowing drug dealers, smugglers, terrorists, and arms dealers to maintain control over their proceeds and ultimately to provide a legitimate cover for their sources of income.  The new PCL has made all criminal offences predicate offences for money laundering purposes.
When do I submit an SAR to the FRA?
A SAR should be made as soon as the knowledge or suspicion that criminal proceeds exist has arisen or at the earliest opportunity thereafter.
How do I submit my suspicions to the FRA?
In late 2020, the Financial Reporting Authority (FRA) launched its AMLive Reporting Portal (the Portal), which allows Reporting Entities to submit Suspicious Activity Reports (SARs) electronically.  Reporting Entities are being registered and provided with their user credentials for the Portal. Once a Reporting Entity receives its user credentials, subsequent SARs should be submitted via the Portal.
In the event a Reporting Entity is not registered, SARs should continue to be submitted through the FRA’s email address ( using the Suspicious Activity Report (SAR) Form and must be password protected. The password can be provided via a voice message at the extension (345) 244-5711.
If you have any queries, feel free to call (345) 244-5711 or (345) 945-6267, or email
Acknowledgement Letters
The FRA provides an acknowledgement in writing on receipt of any SAR received by fax, post, email or hand delivered.