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1.3.2. Protection for Individuals Disclosing Suspicious Activity

Effective from 7/6/2021

LFIs as well as their board members, employees, and authorized representatives, are protected by Article 15 of the AML-CFT Law and Article 17.3 of the AML-CFT Decision from any administrative, civil, or criminal liability resulting from their good-faith performance of their statutory obligation to report suspicious activity to the FIU. This is also the case even if they did not know precisely what the underlying criminal activity was, and regardless of whether illegal activity actually occurred. This covers cases when an employee files an STR, SAR, or other report types that its employer did not want to file.

However, it should be noted that such protections do not extend to the unlawful disclosure to the customer or any other person, whether directly or indirectly, that they have reported or intend to report a suspicious transaction, or of the information or data the report contains, or that an investigation is being conducted in relation to the transaction.