Reporting an unusual transaction: what, when, how
The reporting duty to the FIU, the tipping-off rule, and how the file protects you.
Executive summary
Suspicion is a legal threshold, not a certainty threshold.Tipping off is prohibited.Since 30 September 2024 Belgian reports use goAML, with lawyer Bar-filter routes where applicable.When you know, suspect or have reasonable grounds to suspect money laundering or terrorist financing, you must report to the financial intelligence unit — in Belgium, CTIF-CFI — promptly, and before completing the transaction where possible.
You may not tip off the client that a report has been or may be made. For lawyers, Belgian law routes certain reports through the Bar, preserving a filtering role; for other professions the report goes directly.
A complete, dated file is your protection: it shows the basis for the decision, whether to report or not. Reporting in good faith carries legal protection; failing to report a clear suspicion does not.
Who this applies to
This guide is for offices that may encounter facts suggesting money laundering, terrorist financing, sanctions evasion or predicate offences during onboarding, execution or ongoing monitoring.
- Unusual source-of-funds explanations
- Complex structures without a clear rationale
- Client pressure to rush or avoid documentation
- Sanctions, fraud, corruption or tax-crime indicators
- Suspicion discovered after acceptance
Legal and supervisory context
The reporting duty is triggered by knowledge, suspicion or reasonable grounds to suspect. The office does not need to prove a crime; it needs to decide whether the suspicion threshold has been met and, if so, report through the proper route.
In Belgium, CTIF-CFI moved suspicious transaction reporting to goAML from 30 September 2024. Lawyers have a specific route through the Bar for certain cases, preserving the filtering role and privilege-sensitive handling.
What the office must actually do
The office should stop and escalate internally, avoid tipping off, prepare a clear narrative, file through the correct route, and keep the evidence of what was decided and when.
- Capture the facts and red flags.
- Escalate to the AMLCO or responsible professional.
- Prevent client-facing language that tips off.
- Decide report/no-report with reasons.
- Prepare the goAML XML or lawyer Bar referral pack.
- Record filing acknowledgement or no-report rationale.
What good evidence looks like
The file should contain the red flags, narrative, decision-maker, route, filing package, acknowledgement and follow-up history, with access controls because STR work is highly sensitive.
Common mistakes supervisors find
- Waiting for certainty before reporting.
- Discussing possible reporting with the client.
- Keeping the suspicion narrative only in email.
- Using the wrong route for Belgian lawyer matters.
- Not recording why a no-report decision was made.
Practical checklist
- Record unusual facts.
- Escalate internally.
- Restrict access.
- Avoid tipping off.
- Prepare narrative and evidence.
- Use goAML or Bar route as applicable.
- Store acknowledgement and follow-up.
- Creates STR drafts from file evidence.
- Prepares goAML-ready XML for office filing.
- Supports Belgian lawyer Bar referral packs.
- Logs access to sensitive reports.
- Keeps report and no-report decisions replayable.
FAQ
Do I need proof of a crime before reporting?
No. The threshold is suspicion or reasonable grounds to suspect, not proof beyond doubt.
Can I tell the client why the file is delayed?
You must avoid tipping off. Any client communication should be carefully controlled.
Does Sceau become the reporting entity?
No. Sceau prepares and records the workflow. The obliged entity remains responsible for filing through its own route.
Official references
From knowledge to compliance
Reading is a start. Sceau turns these obligations into a workflow that runs itself and proves itself.
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