How to identify a Suspicion?

An effective systemic approach to identify suspicious financial activity may safeguard you and your institution, business or profession from the risk of being involved with terrorist financing and money laundering crimes. Consider the “SAFE” approach which may assist you in legal compliance and staff training.

Examination of the STR's received by the JFIU reveals that many reporting institutions do not use the system outlined above. Commonly, institutions make an STR merely because a suspicious activity indicator has been recognized, i.e. only step (1) of the systemic approach is followed, steps (2), (3) and (4) are not followed. This failure to use the systemic approach leads to a lower quality of STRs.

Each of the four steps of the systemic approach to suspicious activity identification are discussed in more detail in the following paragraphs.


When to submit an STR?

The laws state that when a person knows or suspects that any property is proceeds of drug trafficking or an indictable offence, or terrorist property, or was used in connection with drug trafficking, an indictable offence or terrorist act, or is intended to be used in drug trafficking, an indictable offence or terrorist act, he or she should report his or her knowledge or suspicion to an authorized officer (i.e. the JFIU) as soon as practicable.


How to submit an STR?

Suspicious transaction reports can be made in one of the following ways:

  • by fax to : (852) 2529 4013
  • by mail, addressed to Joint Financial Intelligence Unit, GPO Box 6555 Hong Kong
  • by telephone (852) 2866 3366 (for urgent reports during office hours)

If you want to file an STR via STREAMS, you have to complete the application form and return to the JFIU either by fax (2529 4013) or email (jfiu@police.gov.hk). If you need any further information, please feel free to contact the JFIU.


What to Report in an STR?

An STR should include the following details:

  • personal particulars (name, identity card or passport number, date of birth, address, telephone number, bank account number) of the person(s) or company involved in the suspicious transaction;

  • details of the suspicious financial activity;

  • the reason why the transaction is suspicious - which suspicious activity indicators are present?

  • the explanation, if any, given by the person about the transaction

In order to ensure that all relevant information is included in the STR, a proforma has been designed to assist STR makers. Click here to download a copy of the proforma.


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