Suspicious Transaction Reporting

If a member determines, when acting for a client in a transaction, that he has any information that confirms or gives reason to suspect that any property represents criminal proceeds (including terrorist related property), or will be used in connection with a criminal offence, then he has a legal obligation to file a Suspicious Transactions Report (“STR”) with the Joint Financial Intelligence Unit (“JFIU”).

1. How to Submit a Suspicious Transaction Report?

   All STRs must be submitted electronically through the Suspicious Transaction Report and Management System (“STREAMS 2”).
   STREAMS 2 is the JFIU’s electronic system for submitting, processing and analysing suspicious transaction reports.
   Under STREAMS 2, law firms may submit STRs using one of the following methods:
   1. XML submission
      
      • STRs may be submitted in XML format.
      • A Hongkong Post e-Cert is required.
   2. STR PDF Form submission
      
      • A completed STR in the prescribed PDF format may be uploaded in STREAMS 2.
      • A Hongkong Post e-Cert is required.
   3. STREAM 2 Online web-form submission 
      • STRs may be completed and submitted directly using the web-form available within STREAMS 2.
   Important: To submit STR via STREAM 2 (option c), you must first obtain login credentials by registering with the JFIU.
   Members are strongly encouraged to register for STREAMS 2 access as soon as practicable to ensure that STRs can be submitted without delay when required. Further details on the registration process are set out in point 2 below.

2. STREAMS 2 Registration Guidance

   To submit a STR via STREAMS 2, you have to first apply for a secure area login and password for STREAMS 2 from the JFIU, please click here.
   
   After completion of the User Registration Form, please send the form to jfiu@police.gov.hk via the applicant’s registered email address. The application result will be sent to the applicant’s registered email address.

3. STR Proforma

   Please click here.

4. What to Report in an STR?

   An STR should include the following details :
   1. personal particulars (name, identity card or passport number, date of birth, address, telephone number, bank account number) of the person(s) or company involved in the suspicious transaction;
   2. details of the suspicious financial activity;
   3. the reason why the transaction is suspicious - which suspicious activity indicators are present?
   4. the explanation, if any, given by the person about the transaction

For enquiries, please contact the JFIU by telephone (852) 2866 3366 or by email to jfiu@police.gov.hk.