Why STRs Matter More Than Ever
A Suspicious Transaction Report (STR) is one of the most powerful tools in the fight against money laundering, terrorism financing, and financial crime. But here’s the challenge: too many STRs are either overloaded with irrelevant details or so vague that investigators can’t act on them.
An STR is not just a compliance checkbox. It’s a story — one that should allow investigators to quickly understand who is involved, what happened, and why it’s suspicious. Done well, it can trigger investigations that stop financial crime at scale. Done poorly, it gets lost in the noise.
So how do you write a strong STR? Let’s break it down.
1. Start With the Who
Clearly identify the subject(s) of the report:
- Full legal names, aliases, and identifiers (DOB, nationality, addresses, IDs).
- Account numbers, relationship history, and beneficial ownership links.
💡 Tip: If the customer is part of a larger network, highlight their connections upfront. Don’t make the investigator dig.
2. Describe the What (Suspicious Activity)
Don’t just say “suspicious transaction.” Spell it out:
- Was it unusual cash deposits?
- Rapid movement of funds across borders?
- Use of shell entities or unusual trade routes?
Be factual and concise. Replace vague phrases like “seemed unusual” with concrete observations such as “customer deposited $9,900 in cash 12 times over 14 days.”
3. Provide the When (Timeline)
Criminals often use patterns. Investigators need dates, times, and sequencing:
- When did the activity occur?
- Was it linked to other events (e.g., account opening, external news)?
- Is the suspicious behavior ongoing or isolated?
4. Add the Where (Geography)
Geography matters in AML. Mention:
- Countries involved in the transactions.
- High-risk jurisdictions (offshore hubs, sanctioned regions).
- Any unusual trade routes or shipping patterns.
5. Explain the How (Method)
This is where you outline the laundering technique:
- Structuring (smurfing small deposits).
- Layering (funds moved through multiple entities).
- Shell companies, nominee directors, or crypto wallets.
⚖️ 6. Justify the Why (Risk Rationale)
Investigators want to know why you think this matters. Link your observation to typologies or regulatory red flags:
- “The pattern resembles classic structuring designed to avoid reporting thresholds.”
- “Funds were routed via a known high-risk jurisdiction without business justification.”
📎 7. Attach Supporting Evidence
The strength of an STR lies in the evidence. Attach:
- Transaction records.
- Customer KYC documents.
- Emails, invoices, or communications.
- Screenshots of adverse media or registry extracts.
Think of Your STR as a Story
The best STRs tell a clear story: who, what, when, where, how, and why. Investigators should be able to follow the logic without guesswork.
Remember, your report might be one of thousands received that week. Make yours stand out for clarity and quality.
Final Takeaway
A strong STR is not just compliance paperwork — it’s your contribution to global financial integrity. The better your report, the higher the chance it triggers meaningful action.
Write it like someone’s investigation depends on it — because it often does.