If you suspect money laundering or terrorist financing, report the suspicious or unusual business transaction to the Financial Intelligence Unit (FIU). Such a report must be filed without delay, to ensure that the funds are not transferred beyond the authorities’ reach. The Financial Intelligence Unit may also be contacted by telephone or e-mail.
A report on money laundering does not constitute a report of an offence, and does not call for knowledge of the nature or essential elements of the offence or penal code.
A suspicious business transaction may be discovered only afterwards. The reporting obligation also applies to these situations, and failure to report is a punishable act.
Reporting a suspected case of money laundering is an exception to secrecy obligation. A supervised entity is not made liable for financial damage incurred by customers, for instance, as a result of suspension or examination of a business transaction or filing of a report on the transaction to the Financial Intelligence Unit, provided that the supervised entity has proceeded with due care.
When to suspect and report?
The background of a business transaction needs to be clarified, for example, in the following situations:
- The business transaction deviates from the ordinary in terms of its size or structure.
- The business transaction has no apparent financial purpose.
- The business transaction conflicts with the customer’s financial position or business activity.
A report to FIU must be filed at least in the following situations:
- Un unusual business transaction appears suspicious even after clarification has been requested from the customer.
- A suspicious business transaction is discovered afterwards or something turns up later that renders the business transaction suspicious.
- The service provider carries out a suspicious business transaction, because refusal to do so would complicate examinations with regard to the beneficiary or the case.
- The service provider refuses to carry out an unusual or suspicious business transaction.