A Suspicious Transaction Report (STR) is one of the most important reporting obligations under the Financial Intelligence Centre Act 38 of 2001 (FICA). Under FICA s.29, every accountable institution must file an STR with the Financial Intelligence Centre (FIC) when it knows, suspects, or has reasonable grounds to suspect that a transaction or attempted transaction involves the proceeds of unlawful activities, money laundering, terrorist financing, or proliferation financing. The obligation arises regardless of the transaction amount — there is no minimum threshold. Failure to file an STR is a sanctionable offence under FICA s.45C, carrying administrative penalties of up to R50 million per contravention.
What Triggers the STR Obligation?
The STR obligation under FICA s.29 is triggered by knowledge, suspicion, or reasonable grounds to suspect — not by certainty. An institution does not need to prove that a transaction involves proceeds of crime before filing an STR. The standard is whether a reasonable person in the institution's position, with the same knowledge and information, would suspect that the transaction is suspicious.
| Trigger | FICA Reference | Description |
|---|---|---|
| Proceeds of unlawful activities | FICA s.29(1)(a) | The institution knows, suspects, or has reasonable grounds to suspect that a transaction or attempted transaction involves the proceeds of any unlawful activity. |
| Money laundering | FICA s.29(1)(b) | The institution knows, suspects, or has reasonable grounds to suspect that a transaction is designed to facilitate money laundering. |
| Terrorist financing | FICA s.29(1)(c) | The institution knows, suspects, or has reasonable grounds to suspect that a transaction involves the financing of terrorist activities or a terrorist organisation. |
| Proliferation financing | FICA s.29(1)(d) | The institution knows, suspects, or has reasonable grounds to suspect that a transaction involves the financing of the proliferation of weapons of mass destruction. |
| Attempted transactions | FICA s.29(1) | The obligation applies to attempted transactions. If a customer attempts a suspicious transaction and then withdraws, the institution must still file an STR. |
The 15-Day Filing Deadline
Under FICA s.29(2), an accountable institution must file an STR within 15 days of becoming aware of the facts that give rise to the suspicion. The 15-day period runs from the date the institution first becomes aware of the suspicious facts — not from the date the transaction occurred, and not from the date the compliance officer reviews the escalation. Internal escalation procedures must be fast enough to allow the compliance officer to review, decide, and file within the 15-day window.
The FIC treats late filing as a separate contravention from non-filing. An institution that files an STR after the 15-day deadline has still failed to comply with FICA s.29(2) and may be subject to administrative sanctions, even if the STR is eventually filed.
Cash Threshold Reports (CTRs): The Companion Obligation
In addition to STRs, FICA s.28 requires accountable institutions to file a Cash Threshold Report (CTR) for any cash transaction above R49,999 (or a series of linked transactions that together exceed R49,999). A CTR is triggered by the transaction amount alone — no suspicion is required.
| STR (FICA s.29) | CTR (FICA s.28) | |
|---|---|---|
| Trigger | Suspicion of ML/TF/PF or proceeds of crime | Cash transaction above R49,999 |
| Threshold | No minimum — any amount | R49,999 (cash only) |
| Deadline | 15 days from awareness | 2 days from transaction date |
| Transaction type | Any transaction (cash, EFT, crypto, etc.) | Cash transactions only |
| Suspicion required? | Yes — knowledge, suspicion, or reasonable grounds | No — amount alone triggers the obligation |
| Filing platform | goAML | goAML |
Red Flags: What Should Trigger a Suspicion?
The FIC has published guidance on the types of behaviour and transaction patterns that should give rise to a suspicion and trigger the STR obligation. The following categories cover the most common red flags identified in FIC inspection reports and enforcement actions.
- Customer Behaviour▲
- Customer is unusually secretive about the purpose of the transaction
- Customer provides inconsistent or implausible explanations for the transaction
- Customer is reluctant to provide identification or beneficial ownership information
- Customer asks about reporting thresholds or how to avoid reporting
- Transaction Patterns▼
- Source of Funds▼
- Business Activity▼
The Tipping-Off Prohibition: FICA s.32
FICA s.32 prohibits any person who has filed or is about to file an STR from disclosing to any other person — including the customer — that an STR has been or will be filed, or that the FIC is investigating the matter. The tipping-off prohibition applies to all employees of the institution, not just the compliance officer. Key points:
- Criminal offence: Tipping off is a criminal offence under FICA s.32, carrying a maximum penalty of 15 years imprisonment or a fine, or both.
- Applies to all employees: Any employee who discloses the existence of an STR — even inadvertently — may be criminally liable.
- Applies before and after filing: The prohibition applies from the moment the institution decides to file an STR, not just after the STR has been submitted.
- Does not prevent normal business: The institution may continue the business relationship and conduct normal transactions. The prohibition is on disclosure of the STR, not on the business relationship itself.
- Good-faith protection: FICA s.37 provides protection to persons who file STRs in good faith. A person who files an STR in good faith is not liable for any loss or damage that may result from the report, even if the suspicion turns out to be unfounded.
How to File an STR via goAML
All STRs must be filed electronically via the FIC's goAML platform. STRs cannot be filed by email, fax, or post. The following six steps cover the goAML filing process.
Register on goAML
Register the institution on the FIC's goAML platform at goaml.fic.gov.za. Designate a reporting officer and obtain login credentials. Registration is mandatory for all accountable institutions.
Identify the Suspicious Transaction
Document the facts that give rise to the suspicion: the transaction details, the customer's explanation (if provided), the red flags identified, and the basis for the suspicion. Retain all supporting documentation.
Escalate to the Compliance Officer
Escalate the suspected transaction to the compliance officer or designated reporting officer. The compliance officer must review the escalation and make the final decision on whether to file an STR.
File the STR on goAML
Log in to goAML and complete the STR form. Include all required fields: customer details, transaction details, the nature of the suspicion, and any supporting information. Submit within 15 days of becoming aware of the suspicious facts.
Retain the goAML Reference Number
Retain the goAML reference number generated upon submission as evidence of filing. Record the filing date, the reference number, and the name of the person who filed the report in the institution's STR register.
Do Not Tip Off the Customer
Do not disclose to the customer or any other person that an STR has been filed. Do not take any action that would alert the customer to the filing. Continue the business relationship unless directed otherwise by the FIC or a court order.
STR Policy in the RMCP
The institution's RMCP must document the STR and CTR reporting policy, including:
- The internal escalation procedure for suspected transactions (who to escalate to, within what timeframe).
- The compliance officer's decision-making process for STR filing.
- The goAML filing procedure and the 15-day deadline.
- The tipping-off prohibition and staff training requirements.
- The STR register (log of all STRs filed, with goAML reference numbers and filing dates).
- The CTR filing procedure and the 2-day deadline for cash transactions above R49,999.
The FIC will review the RMCP STR policy during an inspection and cross-reference it against the institution's STR register. An institution that has never filed an STR will be scrutinised carefully — the FIC considers a zero-STR history to be a red flag indicating that the institution's transaction monitoring programme is not functioning effectively.
Frequently Asked Questions
- What is a Suspicious Transaction Report (STR) under FICA?▼
- How long does an accountable institution have to file an STR?▼
- What is the tipping-off prohibition under FICA?▼
- What is a Cash Threshold Report (CTR) and how does it differ from an STR?▼
- How do you file an STR with the FIC?▼
- What happens after an STR is filed?▼