The document outlines best practices for detecting and reporting suspicious activity by designated non-financial businesses and professionals (DNFBP), emphasizing training employees in reporting and compliance with anti-money laundering (AML) procedures. Key indicators of suspicious activity include unusual transactions, insufficient customer information, and unexplained wealth, necessitating thorough staff training and collaboration to mitigate risks. Organizations should maintain updated records and stay informed on regulatory changes to enhance their ability to identify and report such activities.

1. Ensuring Effective Suspicious
Activity Reporting
To ensure effective suspicious activity reporting, DNFBP should follow the best
practices below:
a. Software for transaction monitoring can be used to highlight unusual
behavior.
b. Make sure that every employee, especially those who deal with clients,
is knowledgeable with SAR protocols, rules, and common dangers.
c. As quickly as you can, report any potentially suspicious conduct.
d. Maintain a record of all SARs to ensure oversight of the reporting
process and keep it up to date.
e. Conduct an in-depth investigation and analysis to learn as much as you
can about the conceivably suspicious behavior.

2. f. Investigate suspicious activity thoroughly and in a timely manner.
In addition, DNFBP should establish and maintain an effective anti-money
laundering (AML) program, which includes procedures for detecting and reporting
suspicious activity. To track and spot anomalous activity, the proper policies,
procedures, and processes must be in place.
Compliance officers should also be trained to identify suspicious activity, even if it
does not involve hard evidence. Finally, organizations can improve their awareness
and reporting of suspicious activity by staying current with regulatory requirements
and using tools to stay compliant.
Risk Indicators Suggesting Suspicious Activities
DNFBP and regulatory bodies are constantly on the lookout for red flags that signal
potential suspicious activity. These red flags are differentiated according to the
client, source of funds, choice of lawyer, nature of retainer, etc.
Here are some common risk indicators suggesting suspicious activity:
1. Insufficient or Suspicious Information: Customers who provide
insufficient or suspicious information may be trying to conceal their
identity or the true nature of their business.
2. Unusual Transactions: Transactions that are unusual for the
customer or the type of business they are engaged in may indicate
suspicious activity. This could include sudden unanticipated
changes in a customer’s transaction pattern, using an unusual
number of large denomination bills in cash transactions, or parties
involved in the transaction being located in a high-risk country.
3. Avoiding the Record-Keeping System: Customers who try to
avoid the record-keeping system, such as by insisting on paying in
cash or using multiple accounts, may be trying to conceal their
transactions

3. 4. Multiple Accounts: Customers who have multiple accounts with the
same financial institution, or with different institutions, may be
trying to spread out their transactions to avoid detection
5. Unusual Source of Funds: Transactions that involve an unusual
source of funds, such as a third party or an offshore account, may
indicate suspicious activity
6. Unexplained Wealth: Customers who have unexplained wealth or
who engage in transactions that do not match their known income or
assets may be engaging in suspicious activity.
7. Large Value Transactions: Customers who suddenly start making
large value transactions, contrary to the transaction history, may
indicate suspicious activity.
Employees’ Roles in Detecting ML/FT-related
Suspicious Activities
Employees play a crucial role in detecting ML/FT-related suspicious activity.
Here are some crucial details about their function:
1. Training: Employees need to be trained on ML/FT risk indicators,
identifying suspicious activities, and appropriately reporting them
to the relevant authorities, such as the Financial Intelligence Unit
(FIU). AML training is critical for employees to act as a line of
defense and contribute to making the company a hostile setting for
money laundering.
2. Knowledge of Indicators: Employees should be familiar with
ML/FT indicators and typologies to quickly identify potential
threats in routine business operations. These indicators, combined
with facts and context, can help determine if there are reasonable
grounds to suspect that a transaction is related to ML/FT offenses.

4. 3. Reporting: Employees should know the process for identifying,
investigating, and reporting suspicious transactions to the
appropriate authorities, as specified in the company’s policies and
procedures. Prompt and accurate reporting is crucial in combating
ML/FT activities.
4. Collaboration: Employees should collaborate with their colleagues
and relevant departments to share information and identify patterns
or abnormal behavior that may indicate ML/FT activities. This can
involve global transaction monitoring, alert processing, and
checking for similar behavior across different transactions.
By fulfilling these roles, employees can contribute to the detection and prevention
of ML/FT-related suspicious activity, helping to safeguard the company and the
financial system as a whole.
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