# AMLR Art. 69 — Reporting of suspicions > Since 1 October 2026 the definition of 'begründeter Verdacht' is GwG Art. 9 Abs. 1quinquies (text unchanged, formerly Abs. 1quater). See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** [[FATF R.20 - Reporting of suspicious transactions|FATF R.20]] - **Swiss provisions:** [[GwG Art. 9 - Duty to report (to MROS)|GwG Art. 9]] - **Detailed citation:** GwG Art. 9 Abs. 1; Abs. 1quinquies (definition of begruendeter Verdacht) ## What it requires AMLR Art. 69 requires obliged entities to cooperate fully with the FIU: report on their own initiative wherever they know, suspect or have reasonable grounds to suspect that funds or activity, regardless of amount, are proceeds of crime or linked to terrorist financing (Para 1(a)), and answer FIU information requests within 5 working days (extendable). The compliance officer transmits reports (Para 6); staff involved in reporting are protected against retaliation (Para 7). ## Swiss position GwG Art. 9 Abs. 1 requires intermediaries to report to MROS (Art. 23) without delay where they know or have 'begründeten Verdacht' (founded suspicion) that relationship assets link to predicate offences, organised/terrorist crime, or terrorist financing (Bst. a), where they break off negotiations on that suspicion (Bst. b), or the data of a client, beneficial owner or signatory match terrorism-related data forwarded under Art. 22a (Bst. c). Abs. 1quinquies defines 'begründeter Verdacht': a concrete indication or several grounds that Bst. a could be met, undispelled by further Art. 6 clarification. GwG Art. 9b Abs. 1 lets the intermediary terminate the relationship if MROS does not confirm within 40 working days that it forwarded the report to a prosecutor. StGB Art. 305ter Abs. 2 is treated throughout GwG (Art. 9a, 10, 11, 11a, 23) as a parallel reporting basis for persons outside GwG's own duty. ## Key divergences AMLR Art. 69(1)(a) triggers on 'knows, suspects or has reasonable grounds to suspect'; GwG Art. 9 Abs. 1 triggers on 'weiss oder den begründeten Verdacht hat' (knows or has founded suspicion), which Abs. 1quinquies defines as a concrete indication or several grounds that predicate-offence assets are involved, not dispelled by further Art. 6 inquiry. AMLR keeps 'suspects' and 'reasonable grounds to suspect' as two express, separate limbs, whereas GwG's single Abs. 1quinquies test folds both into one concrete-indication-plus-unresolved-doubt standard. GwG's structure also keeps a reporting right (StGB Art. 305ter Abs. 2) distinct from the reporting duty (Art. 9) - a two-track model AMLR Art. 69, a single mandatory-reporting provision, does not have. AMLR Art. 69 expressly covers attempted transactions and CDD-failure suspicions (Para 1, second subparagraph); GwG Art. 9 Abs. 1 Bst. b covers part of this, requiring a report where negotiations to open a business relationship are broken off because of a founded suspicion. The joint-reporting option for partnerships for information sharing (Para 8–9) has no counterpart in GwG Art. 9. ## Effective dates Since 1 October 2026 the definition of 'begründeter Verdacht' is GwG Art. 9 Abs. 1quinquies (text unchanged, formerly Abs. 1quater). See [[Effective-dates timeline]]. ## Further connections *These links come from an article-by-article comparison of the primary texts. They add to the provisions listed at the top of this note and make no equivalence claim.* - [[GwG Art. 11a - MROS request for additional information|GwG Art. 11a]] — Both oblige intermediaries to supply further information to the FIU on request. GwG Art. 11a applies only when MROS is analysing a report or foreign-FIU information, and MROS sets the deadline (Abs. 3); AMLR 69(1)(b) is general, with a default reply period of 5 working days that the FIU may shorten or extend. *(direct)* - [[GwV-FINMA Art. 25a - Decision-making authority on reporting|GwV-FINMA Art. 25a]] — Both assign internal responsibility for suspicious-activity reports. AMLR has the compliance officer transmit them; GwV-FINMA places the filing decision with top management, delegable to the AML compliance unit. *(related)* - [[FATF R.29 - Financial intelligence units|FATF R.29 — Financial intelligence units]] — R.29 requires the FIU to be able to obtain additional information from reporting entities; Art. 69(1)(b) sets the corresponding duty of obliged entities to supply it. *(related)* - [[StGB Art. 305ter - Lack of due diligence and right to report|StGB Art. 305ter]] — AMLR Art. 69 sets only a duty to report; Swiss law adds a right to report under StGB Art. 305ter Abs. 2 alongside the GwG Art. 9 duty. *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 69 — English text (EUR-Lex, CELEX 32024R1624) > **Article 69** > *Reporting of suspicions* > 1. Obliged entities, and, where applicable, their directors and employees, shall cooperate fully with the FIU by promptly: > (a) reporting to the FIU, on their own initiative, where the obliged entity knows, suspects or has reasonable grounds to suspect that funds or activities, regardless of the amount involved, are the proceeds of criminal activity or are related to terrorist financing or criminal activity and by responding to requests by the FIU for additional information in such cases; > (b) providing the FIU, at its request, with all necessary information, including information on transaction records, within the deadlines imposed. > All suspicious transactions, including attempted transactions and suspicions arising from the inability to conduct customer due diligence shall be reported in accordance with the first subparagraph. > For the purposes of the first subparagraph, obliged entities shall reply to requests for information by the FIU within 5 working days. In justified and urgent cases, FIUs may shorten that deadline, including to less than 24 hours. > By way of derogation from the third subparagraph, the FIU may extend the deadline for a response beyond the 5 working days where it considers it justified and provided that the extension does not undermine the FIU’s analysis. > 2. For the purposes of paragraph 1, obliged entities shall assess transactions or activities carried out by their customers on the basis of and against any relevant fact and information known to them or which they are in possession of. Where necessary, obliged entities shall prioritise their assessment taking into consideration the urgency of the transaction or activity and the risks affecting the Member State in which they are established. > A suspicion pursuant to paragraph 1, point (a), shall be based on the characteristics of the customer and their counterparts, the size and nature of the transaction or activity or the methods and patterns thereof, the link between several transactions or activities, the origin, destination or use of funds, or any other circumstance known to the obliged entity, including the consistency of the transaction or activity with the information obtained pursuant to Chapter III including the risk profile of the client. > 3. By 10 July 2026, AMLA shall develop draft implementing technical standards and submit them to the Commission for adoption. Those draft implementing technical standards shall specify the format to be used for the reporting of suspicions pursuant to paragraph 1, point (a), and for the provision of transaction records pursuant to paragraph 1, point (b). > 4. Power is conferred on the Commission to adopt the implementing technical standards referred to in paragraph 3 of this Article in accordance with Article 53 of Regulation (EU) 2024/1620. > 5. By 10 July 2027, AMLA shall issue guidelines on indicators of suspicious activity or behaviours. Those guidelines shall be periodically updated. > 6. The compliance officer appointed in accordance with Article 11(2) shall transmit the information referred to in paragraph 1 of this Article to the FIU of the Member State in whose territory the obliged entity transmitting the information is established. > 7. Obliged entities shall ensure that the compliance officer appointed in accordance with Article 11(2), as well as any employee or person in a comparable position, including agents and distributors, involved in the performance of the tasks covered by this Article are protected against retaliation, discrimination and any other unfair treatment for carrying out those tasks. > This paragraph shall not affect the protection that the persons referred to in the first subparagraph may be entitled to under Directive (EU) 2019/1937. > 8. Where the activities of a partnership for information sharing result in the knowledge, suspicion or reasonable grounds to suspect that funds, regardless of the amount involved, are the proceeds of criminal activity or are related to terrorist financing, obliged entities which identified suspicions in relation to the activities of their customers may designate one among them which shall be tasked with the submission of a report to the FIU pursuant to paragraph 1, point (a). Such submission shall include at least the name and contact details of all the obliged entities that participated in the activities giving rise to the report. > Where the obliged entities referred to in the first subparagraph are established in several Member States, the information shall be reported to each relevant FIU. To that end, obliged entities shall ensure that the report is submitted by an obliged entity within the territory of the Member States where the FIU is located. > Where the obliged entities decide not to avail themselves of the possibility to submit a single report with the FIU pursuant to the first subparagraph, they shall include a reference in their reports to the fact that the suspicion is the result of the activities of a partnership for information sharing. > 9. The obliged entities referred to in paragraph 8 of this Article shall retain a copy of any reports submitted pursuant to that paragraph in accordance with Article 77. ## Sources - AMLR Art. 69 — CELEX 32024R1624 - GwG SR 955.0, Art. 9, Art. 9b