Suspicious Transactions: What You Don’t Report Can Hurt You

8 Aug

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If a transaction doesn’t look right, report it. Your reputation, and even your freedom could be at stake.

Most accountants didn’t choose this profession to be investigators. But if you’re a Business Accountant in Practice (BAP(SA)) or Certified Business Accountant in Practice (CBAP), the Financial Intelligence Centre Act (FIC Act) gives you clear legal duties in the fight against money laundering.

You don’t need to be a bank to be affected. The FIC Act applies to anyone carrying on a business—including accountants in private practice, advisory roles, or finance teams. Ignoring these obligations can lead to severe penalties, including heavy fines or imprisonment.

Recognising the Warning Signs

Suspicious transactions are not always obvious. They rarely come with clear labels, but there are signs you can watch for:

Transactions with no clear business purpose
Clients who seem unconcerned about losing money or breaking rules
Unusual or unjustified international payments
Deals or fees that are far above or below market rates
Trusts or offshore structures without a clear commercial reason
Attempts to avoid documentation or split payments to evade reporting requirements

If something doesn’t make commercial sense, treat it as suspicious. The law says you must act if you suspect—or should reasonably suspect—something is wrong.

How to Respond to Suspicious Activity

Report internally first
Speak to your compliance officer or the person responsible for FIC reporting. You are legally protected when you raise concerns in good faith.
Submit a Suspicious Transaction Report (STR)
Use the goAML system to report within 15 business days of identifying the concern. The deadline starts the moment you notice a red flag.
Do not alert the client
Tipping off a client or anyone else is a criminal offence. Keep all discussions confidential.
Keep detailed records
Document what you saw, why you were concerned, and the actions you took. This could be vital if regulators investigate.
Assist authorities if required
Cooperate with the Financial Intelligence Centre or law enforcement, and continue to monitor client activities.

No Minimum Amount

Whether it’s R500 or R5 million, if it’s suspicious, it must be reported. Failure to comply can result in:

Up to 15 years’ imprisonment
Fines of up to R10 million
Administrative penalties from your regulator

The Role of CIBA Members

Your role goes beyond preparing financial statements. You are a key line of defence in protecting your clients, your practice, and the integrity of the financial system.

If you report in good faith, the law protects you. Acting on suspicion is part of your professional duty—and it safeguards your career.