Suspicious Transaction Report (STR): When, How and to Whom
One of the most critical — and legally significant — obligations: exactly when must you file a Suspicious Transaction Report, and what are you strictly prohibited from saying afterwards.
What Is an STR and Why Is It Mandatory?
A Suspicious Transaction Report (STR) is the mandatory notification of competent authorities when a professional suspects that a client's transaction or activity is connected with money laundering or terrorist financing. Under Article 38 L.4557/2018, the obligation to file an STR is immediate — you do not need certainty, "reasonable suspicion" is sufficient. Important: Failing to file an STR when required is an offence and carries severe penalties. By contrast, filing an STR in good faith gives you legal protection — even if it later turns out there was no problem.
Which Behaviour Is Considered 'Suspicious'?
There is no exhaustive list — the law intentionally uses broad language. Indicative categories of red flags: Unexplained capital flows: Large transfers from/to unusual countries without commercial logic. Payment structuring to avoid reporting: Multiple small payments instead of one large one ("structuring"). Economic profile inconsistency: The client declares low income but manages large amounts. Refusal to provide documents: The client refuses to provide KYC documents without reasonable explanation. Connection to a tax evasion or fraud case: Even if it does not involve laundering, it may constitute grounds for a report.
Where to File an STR: The goAML Platform
In Greece, the STR is submitted to the Anti-Money Laundering Coordination Unit (AMLCU) — Financial Intelligence Unit. Since 2022, submission is made via the electronic platform goAML (goaml.amlcu.gr), which requires: • Registration of the professional as a reporting entity • Completion of a structured report (subject, transaction details, grounds for suspicion) • Attachment of supporting documents The report must be filed "without delay" — in practice within 24–48 hours of the suspicion arising.
What Is Prohibited After an STR: Tipping-Off
Article 39 L.4557/2018 — prohibition on disclosure (tipping-off): It is strictly prohibited to inform the client or third parties that an STR has been filed against them or that an investigation has begun. This means: • Do not say "why" you are requesting additional documents if the reason is the STR • Do not disclose that the transaction is under review • Do not discuss the matter with a colleague representing the client Violating the tipping-off prohibition is a criminal offence. Protection: A professional who files an STR in good faith enjoys legal protection from civil or criminal claims by the client (Article 40 L.4557/2018).