STR is a report that a Reporting Institution  is required to submit to the Financial Intelligence and Enforcement Department (FIED), Bank Negara Malaysia whenever the reporting institutions suspects or has reasonable grounds to suspect that the transaction (including attempted or proposed), regardless of the amount:

1. appears unusual;
2. has no clear economic purpose;
3. appears illegal;
4. involves proceeds from an unlawful activity or instrumentalities of an offence; or
5. indicates that the customer is involved in money laundering (ML) or terrorism financing (TF).

The importance of STRs

STRs provide the financial intelligence unit and, subsequently, law enforcement agencies with valuable information/intelligence of potential criminal activities.

Does the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act (AMLA) reporting requirement contravene secrecy obligations?

Section 20 of the AMLA overrides any other secrecy obligation or restriction on disclosure imposed by any other laws, for the purpose of complying with the provisions under Part IV Reporting Obligations of the AMLA.

Protection for persons reporting the STR and CTR

A person reporting the STR and CTR is protected from any civil, criminal or disciplinary proceedings as long as it is performed in good faith as provided under Section 24 of the AMLA.

When to submit STRs?

The Compliance Officer must ensure that the STR is submitted within the next working day, from the date the Compliance Officer establishes the suspicion.

Red flags that may trigger suspicion

RIs must establish red flags to help them and their employees identify situations which may require STRs to be submitted. These red flags vary depending on the sector and specific business the reporting institution is in. Some examples of the red flags can be found at:

Refer to Appendix 4 of AML/CFT and TFS for FIs

Refer to Appendix 15 of AML/CFT and TFS for DNFBPs and NBFIs

How to submit STRs?

Completed STR forms must be submitted to the Financial Intelligence and Enforcement Department of Bank Negara Malaysia through any of the following channels:

1. E-mail to [email protected]
2. Mail to:
   Director
   Financial Intelligence & Enforcement Department
   ​​​​​​Bank Negara Malaysia
   ​​Jalan Dato’ Onn
   50480 (Kuala Lumpur)
   (To be opened by addressee only)
3. Financial Intelligence System (FINS) (where applicable)

Prohibition on tipping off

The Compliance Officer or anybody who has knowledge of an STR must preserve secrecy and should not inform the customer or anyone else that an STR has been or is about to be submitted except if the disclosure is made by a person:

1. to exercise his function under the AMLA;
2. to inform the risks involved in dealing with a particular customer within the financial group of companies in Malaysia;
3. to act in connection with the performance of his duties to the supervisory authority; or
4. with the written authorisation of the competent authority.

Section 14A of the AMLA prohibits against disclosure of reports and related information, failing which a person may be subjected to a fine of not exceeding RM3 million or to imprisonment for a term not exceeding five year or to both.

What makes a quality STR?

The following information must be included in the STR:

1. information on the account holder or client or beneficial owner of the transaction;
2. information on the person conducting the transaction;
3. details of the transaction, such as the type of products or services, the amount involved and review period;
4. a description of the suspicious transaction or its circumstances;
5. suspected offence; and
6. any other relevant information that may assist the Financial Intelligence and Enforcement Department in identifying potential offences and individuals or entities involved.

Suspicious Transaction Report (STR)

Identifying Suspicious Transaction (Red Flags)

Submission of a CTR is required for selected reporting institutions when customers or a person conduct single or multiple cash transactions within the same account in a day for the amount of RM25,000 and above.

Cash transactions refer to or include:

• Transactions involving physical currencies (domestic or foreign currency) and bearer negotiable instruments such as travellers’ cheques and cash cheques but excludes bank drafts, cheques, electronic transfers or fixed deposit rollovers or renewals; and
• Transactions involving withdrawal of cash from accounts or exchange of bearer negotiable instruments for cash.

Reporting institutions shall not offset the cash transactions against one another. Where there are deposit and withdrawal transactions, the amount must be aggregated. Cash transactions also include cash contra from an account to different account(s) transacted over the counter by any customer.

Who is required to report CTRs?

CTR reporting obligations are currently imposed on banking institutions, selected development financial institutions, Lembaga Tabung Haji and the licensed casino only.

How to submit CTRs?

CTRs are submitted electronically via FINS 

Structuring Offence

Structuring, or ‘smurfing’, is the act of breaking up transactions into smaller amounts to evade reporting requirements such as cash threshold reporting. Structuring is a criminal offence under Section 4A of the AMLA.