Suspicion, not certainty
The reporting system is preventive. It does not require an obliged entity to prove the predicate offence. It requires careful assessment of available facts and reporting when the threshold under the applicable framework is met.
A useful narrative
A good report allows the FIU to understand the persons, activity, chronology, anomalies, checks and reasons for suspicion. Lists of transactions without context or generic wording reduce its intelligence value.
Governance and timeliness
Timelines, responsibilities, access to information and escalation routes should be defined before a case arises. The process must preserve confidentiality and prevent inappropriate disclosure to the customer.
Practical scenario
Illustrative example. Before: ‘customer with unusual transactions and supporting documents attached’. After: ‘between March and April, the customer received three payments from counterparties inconsistent with its declared activity and transferred them within 24 hours to a new foreign beneficiary; the explanations obtained do not clarify the economic connection’. The second narrative connects facts, timing, behaviour and the basis for suspicion without unnecessary volume.
Useful check: read the narrative without attachments and ask whether it explains who did what, when, why it is unusual and which checks were already performed.
Sources and references
Informational content. It does not replace an assessment of a specific case.
UIF — Suspicious transaction reportsFIAU — Reporting suspicious activity