On AML and crypto exchanges — when is a 'SAR' triggered?

asked by u/jasmine_p · 3d · 3 answers

I'm trying to get my head around the various AML obligations for crypto exchanges, particularly when dealing with international clients. We're a small operation, just getting licensed in a couple of jurisdictions, and the nuances are proving trickier than anticipated. Specifically, when do you guys typically trigger a Suspicious Activity Report (SAR) in a cross-border scenario? Is it purely based on the transaction amount exceeding a certain threshold, or are there other common red flags you've seen that warrant filing one, even if the amount is relatively small? Just trying to understand the practical implementation beyond the legal text.

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Top answers

  • u/joao.mendoza· 20 pts· 2d

    For cross-border, unusual volumes or patterns without clear business justification, especially with high-risk jurisdictions, often trigger a SAR. Also, any attempts to obfuscate origin of funds or identity.

  • u/anjali29· 9 pts· 2d

    Cross-border SARs are tricky. Beyond the usual red flags, inconsistent KYC data across jurisdictions or sudden large transfers to high-risk countries often trigger ours. What kind of inconsistencies are you seeing?

  • u/yuki_tanaka· 1 pts· 3d

    The SAR threshold isn't really different for international clients; it's still about suspicious patterns of activity, regardless of origin. Focusing on where the funds are going rather than just where they're coming from might be more productive.

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