Financial Institutions and DNFBPs shall put in place indicators that can be used to identify the suspicion on the occurrence of the Crime in order to report STRs, and shall update these indicators on an ongoing basis, as required, in accordance with the development and diversity of the methods used for committing such crimes, whilst complying with what the Supervisory Authorities or FIU may issue instructions in this regard.

1. If Financial Institutions and DNFBPs have reasonable grounds to suspect that a Transaction, attempted Transaction, or funds constitute crime proceeds in whole or in part, or are related to the Crime or intended to be used in such activity, regardless of the amount, they shall adhere to the following without invoking bank secrecy or professional or contractual secrecy:
    
   1. Directly report STRs to the FIU without any delay, via the electronic system of the FIU or by any other means approved by the FIU
       
   2. Respond to all additional information requested by the FIU.
       
2. Lawyers, notary publics, other legal stakeholders and independent legal auditors shall be exempt from Clause (1) of this Article, if obtaining this information regarding such Transactions relates to the assessment of their Customers’ legal position, or defending or representing them before judiciary authorities or in arbitration or mediation, or providing legal opinion with regards to legal proceedings, including providing consultation concerning the initiation or avoidance of such proceedings, whether the information was obtained before or during the legal proceedings, or after their completion, or in other circumstances where such Customers are subject to professional secrecy.
    
3. Financial Institutions and DNFBPs, their board members, employees and authorised representatives shall not be legally liable for any administrative, civil or criminal liability for reporting when reporting to the Unit or providing information in good faith.
    

1. Financial Institutions and DNFBPs, their managers, officials or staff, shall not disclose, directly or indirectly, to the Customer or any other person(s) that they have reported, or are intending to report a Suspicious Transaction, nor shall they disclose the information or data contained therein, or that an investigation is being conducted in that regard.
    
2. When lawyers, notaries, other independent legal professionals, and legal independent auditors attempt to discourage their Customers from committing a violation, they shall not be considered to have made a disclosure.