Suspicious Activity Reporting and Prescribed Transaction Reporting
Suspicious activity reports (SARs)
A reporting entity must report to the FIU where it has reasonable grounds to suspect that a transaction or activity may be money laundering or terrorist financing, or that funds are proceeds of crime. The threshold is suspicion, not proof. A trap is waiting for certainty - the obligation arises on reasonable grounds to suspect. Reports should be made promptly, and internal escalation must be documented.
Prescribed transaction reports (PTRs)
PTRs are threshold-based reports to the FIU. They include cash transactions at or above the prescribed value (currently NZ$10,000 or more, or a series of linked transactions), international wire transfers at or above the prescribed value, and certain suspicious or unusual prescribed transactions. PTRs are automatic and objective - no suspicion is needed - so they are distinct from SARs.
Tipping off and confidentiality
You must not disclose to the customer or others that a SAR has been or will be made where that would prejudice an investigation. This is the tipping-off prohibition. Internal information-sharing within the entity (and to the FIU) is permitted; disclosure outside is not.
Worked example
A customer deposits NZ$10,500 in cash - file a PTR (threshold met) regardless of suspicion. If the same customer is evasive about the source of funds and the pattern is inconsistent with their profile, also file a SAR.
Rule of thumb
PTR = threshold; SAR = suspicion. They can both apply to the same transaction, and neither excuses the other.