Recommendation 20 requires financial institutions to report promptly to the financial intelligence unit when they suspect, or have reasonable grounds to suspect, that funds are proceeds of criminal activity or related to terrorist financing. The standard covers suspicious transactions, including attempted transactions, regardless of amount.

Suspicion reporting is different from routine threshold reporting. A transaction can be suspicious without being large, and a large transaction is not automatically suspicious. Institutions need a process that connects monitoring and staff observations to investigation, an accountable reporting decision and a useful explanation of the suspicious facts.

Related FATF standards address protection for good-faith reporting and restrictions on tipping off. National law determines the competent authority, submission format, deadlines and detailed confidentiality duties. Filing a report also does not by itself answer whether a transaction must be blocked under sanctions law or whether the customer relationship should continue.