Financial Crime World

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Suspicious Activity Reports (SARs)

Who Receives SARs?

Suspicious Activity Reports are made to two entities:

  • Anti Money Laundering Investigations Unit
  • Financial Intelligence Centre for financial institutions

You can visit their website at [link to be provided].

Volume of SARs and GDP Comparison

Unfortunately, information on the volume of SARs is not publicly available.

For comparison, we would need the GDP for the equivalent year. However, this information is also not provided.

Reporting Obligations Beyond Suspicious Transactions

There are no obligations to report anything more than suspicious transactions. Please see our response to Q13 for more information on what constitutes a suspicious transaction.

De-minimis Thresholds

There are no de-minimis thresholds below which transactions do not need to be reported.

Penalties for Non-Compliance

Yes, there are penalties for non-compliance with reporting requirements. These include:

  • Intentionally failing to submit a report to the Centre commits an offence and is liable to a fine not exceeding seven hundred thousand penalty units (approx ZMK126,000,000) or imprisonment for a period not exceeding five years, or both.
  • Knowingly or suspected divulging information about an investigation into money laundering without lawful authority is also an offence and is liable to a fine not exceeding one hundred and thirty-nine thousand penalty units (approximately ZMK25,020,000) or imprisonment for a term not exceeding five years or both.