The bank’s reputation is not a valid criterion for filing a SAR/STR, as it is not related to the objective assessment of the suspiciousness of the transaction or the activity. The bank should file a SAR/STR based on the facts and circumstances of the case, and not on the potential impact on its image or reputation. The other options are possible indicators of money laundering or terrorist financing, and could warrant a SAR/STR filing,depending on the context and the risk profile of the customer and the transaction. For example, a large, round number wire to an obscure organization could suggest an attempt to conceal the source or destination of the funds, or to support a criminal or terrorist entity. A beneficiary that is largely unknown or has no apparent connection to the customer could indicate a lack of transparency or a false identity. A customer activity that is unreasonable or inconsistent with the customer’s profile, business, or expected behavior could indicate a deviation from the normal or legitimate purpose of the account or the transaction.
CAMS Certification Package - 6th Edition, ACAMS, Chapter 5, page 123
CAMS Certifications: How to Get CAMS Certified, ACAMS
Suspicious Activity Reporting — Overview, FFIEC, page 2
3.2. Basic Structure of an STR or SAR, CBUAE Rulebook, page 1
What is a suspicious activity report?, Thomson Reuters
How to decide if SAR filing is needed, Wipfli
STR (Suspicious Transaction Reports), Ministry of Finance, India
