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Suspicious transactions, reporting and records

Free staff training on recognising suspicious patterns, choosing the correct FIC report and preserving inspection-ready evidence.

Where to go next

Use these links to move from learning to the right VerifyNow check or official guidance.

FIC Guidance Note 4BRead the official guidance on section 29 suspicious and unusual transaction reporting.FIC cash threshold reporting FAQCheck the current physical-cash threshold and section 28 reporting guidance.FIC goAML portalOpen the official registration and regulatory reporting portal.FIC Act bookletReview sections 22 to 24 on the records, retention periods and storage rules.

Module 11 · Red flags and suspicion indicators

Identify changes and patterns that may create suspicion.

Red flags and suspicion indicatorsA taxonomy of identity, transaction, behaviour and client-profile red flags. The flow shows staff recording facts, comparing them with the known client and escalating through the organisation's RMCP.Read the change in contextWhat changed about this client or transaction?Compare today's facts with the known purpose and expected activity01Identity and controlBeneficial owner changesUnexplained third partyAuthority is unclear02Transaction patternSplit or structured valuesRapid funds movementUnusual complexity03Behaviour and evidenceUrgency or evasivenessDocuments conflictExplanation keeps changing04Profile and networkActivity shifts from profileNew route or destinationCounterparty lacks a roleStaff responseCapture dates, values, parties and source documentsCompare the facts with the known client and expected activityUse the RMCP escalation route promptlyAn indicator starts a review. Context and combined facts shape suspicion.

Module Quiz

1. What gives a red flag its meaning?

2. Which pattern deserves closer review?

3. What belongs in an internal escalation?

Module 12 · Reporting obligations

Route cash, suspicious activity and terrorist property through the correct report.

Section 28 CTR and section 29 STR decision flowTwo parallel checks compare the physical-cash threshold under section 28 with knowledge or suspicion under section 29. Each trigger has its own reporting period, and both duties can apply to one fact pattern.Choose the report from the triggerWhat facts require a reporting assessment?Run both checks because one event may engage both dutiesPhysical cash above R49 999.99?Coins, paper money or travellers' chequesYes: follow the section 28 routeKnowledge or suspicion under s29?Consider the full transaction or activity contextYes: follow the section 29 routes28 · Cash threshold reportFile through the authorised goAML process.Send as soon as possible, within threebusiness days after awareness.The threshold applies to physical cash.s29 · STR or SARSTR: completed transaction. SAR: activitythat was attempted, aborted or incomplete.Send as soon as possible, within 15 days,excluding weekends and public holidays.Section 29 has no monetary threshold.Where both triggers exist, assess and file each required report.Keep the goAML reference and protect reporting confidentiality.Record a no-trigger decision under the RMCP. Confirmed terrorist property follows the TPR route.

Module Quiz

1. Which transaction reaches the cash-reporting threshold?

2. What monetary threshold applies to a section 29 report?

3. When must a section 29 report be sent?

4. Does a CTR replace an STR when both triggers are present?

Module 13 · Record keeping

Keep retrievable evidence for the required period.

Module Quiz

1. When does the five-year period start for a business-relationship record?

2. When does the five-year period start for a section 29 reporting record?

3. What must apply when a third party stores FICA records?