The Anti-Money Laundering Law and Prakas requires specific Customer Due Diligence measures, including customer identification, to be performed prior to establishing a business relationship and prior to executing a one-off transaction exceeding the threshold and whenever there is a suspicion of money laundering or terrorist financing and whenever doubt exists regarding the veracity of information provided. Therefore, you should update your processes and your records so that the required information is in your possession.

You need to report all the data that you have available to you regarding the transaction in accordance with the CTR or STR specification, respectively.

If you are one of the entities described in Article 1 of the Prakas on Anti-Money Laundering and Combatting the Financing of Terrorism and you or your institution have been party to a transaction or an attempted transaction that meets the criteria specified therein, then you need to submit a report to CAFIU.

Suspicion can have many definitions. For purposes of reporting, suspicion is created when the transaction activity or the behavior of a customer does not match our expectations based on the customer's profile, or when the transaction activity or behavior of a customer matches what we know about criminal offenses and their proceeds. This suspicion persists even after further examination and investigation.

A Cash Transaction Report (CTR) is a report that is submitted when a bank (or other obligated reporting entity) completes a transaction, or a series of linked transactions for a customer or an account that take place within a single day and that involve more than $10,000 USD (40 million Riels) or its equivalent in other currency.

A Suspicious Transaction Report (STR) is a report that is submitted when a bank (or other obligated reporting entity) has reason to suspect that funds are the proceeds of an offense (illicit proceeds) or related to the financing of terrorism.