Filing a Suspicious Matter Report (SMR) is one of the most critical obligations under the AML/CTF Act. Knowing when to file—and just as importantly, when not to—can save your business from regulatory penalties or unnecessary client friction.
Understanding the filing thresholds
The law states you must file an SMR if you form a suspicion on reasonable grounds that a customer or transaction is linked to tax evasion, money laundering, terrorism financing, or any other offence.
“Suspicion does not require proof. It requires a feeling of apprehension or mistrust based on structured facts, flags, or patterns of behaviour.”
Key red flags for reporting
- Unusual transaction patterns:Rapid movements of funds through multiple accounts with no apparent commercial rationale.
- Reluctance to provide KYC data: Clients who push back strongly against verifying UBOs or source of wealth.
- Structuring payments:Keeping deposit sizes intentionally below threshold amounts ($10,000) to avoid reporting triggers.