Writing an STR

In short

A suspicious transaction report (STR) tells the Financial Intelligence Centre (FIC) that you have reasonable grounds to suspect a customer’s funds or activity are linked to crime or terrorist financing. In Ghana, STRs are filed through the FIC’s goAML system.

The most important part is the narrative: a clear story, in plain language, of who did what, when, how, and why it is suspicious. Analysts at the FIC read thousands of reports. A clear narrative gets acted on; a vague one gets filed away.

Confirm the current requirements

Filing deadlines, mandatory fields, attachment formats and the goAML submission process are set by the FIC and change from time to time. Confirm them with current FIC guidance and your MLRO. This page covers how to write a good report, which doesn’t change.

How reports work in SpeculaPro

You draft the STR from the case, so the subject, the transactions and the case’s notes are already there, and a second person approves it before it is filed:

Where the AI assistant is switched on, the draft report offers a draft narrative from the assistant. Treat it as a first draft from someone who hasn’t read your notes: everything on this page still applies, and the narrative is yours.

Stage	What happens
Draft	Someone with reports.draft and entities.view_pii (by default a senior analyst, an L2 investigator or the MLRO) selects Draft STR on the case and writes the report. See Drafting an STR from a case
Awaiting approval	The draft is sent for approval and frozen
Approved · to file	A different person with reports.approve (by default the MLRO) approves it. The database refuses an approval by the person who drafted it or sent it for approval. See Approving a report
Submitted	The report is exported as goAML XML, uploaded in goAML Web, and the FIC’s reference recorded. See Filing with goAML
Acknowledged / Rejected by the FIC	The FIC’s answer is recorded

The case’s timeline links to the report, and the report links back to the case. The report doesn’t close the case: close it yourself with the disposition Report filed.

Check the settings with the FIC first

Before the first real filing, work through Before you go live with your MLRO: SpeculaPro’s goAML codes and thresholds are defaults the FIC hasn’t confirmed for you.

You need two people who can approve

Because the drafter can’t approve their own report, a team with a single MLRO must let someone else draft, such as a senior analyst, or give a second person the MLRO role. See Roles and permissions.

The five Ws and how

A good narrative answers six questions:

Question	What to include
Who	The subject: full name, ID type and number, date of birth or registration, address, phone, account and wallet numbers. Other parties: counterparties, agents, linked customers
What	The activity: transaction types, amounts in GHS, number of transactions, totals
When	Dates and times; the period covered
Where	Branches, agents, locations, countries involved
Why	Why it is suspicious: what doesn’t fit, what you checked, what explanation is missing
How	How the scheme appears to work: structuring, pass-through, use of agents, mules

Structure that works

1. Opening summary (two or three sentences): who, what, how much, over what period, and the suspected typology.
2. Background: who the customer is and what we know about them (occupation, declared activity, how long a customer).
3. The activity: the transactions, in date order, with amounts, and a short table if there are many.
4. Why it is suspicious: the red flags, the checks you made, and why the explanations don’t hold.
5. Actions taken: anything your institution did (enhanced monitoring, account restrictions under policy, linked reports).

Example: a weak narrative

Customer did many transactions which are suspicious. Large amounts came in and went out. Please investigate.

This tells the FIC nothing it can use: no amounts, no dates, no counterparties, no reason.

Example: a strong narrative

The names and numbers below are invented and masked for this example. In a real report, give identifiers in full.

Summary. Between 3 and 21 March 2026, wallet 024•••••89 held by Kwame A. (Ghana Card GHA-•••••••••-3, DOB 14/02/2004), a student in Cape Coast, received GHS 61,350 from 23 unrelated senders and sent GHS 60,900 on to four recipients within hours of each credit. The activity is consistent with the wallet being used as a money mule.

Background. The wallet was opened on 28 January 2026 at an agent in Cape Coast at KYC tier 2. The customer declared his occupation as student and expected monthly activity under GHS 2,000. Before 3 March the wallet’s highest monthly volume was GHS 640.

Activity. Inbound credits ranged from GHS 2,000 to GHS 4,500 (table attached). Three senders have since reported to us that they paid in response to an online advertisement for laptops that were never delivered (complaint refs attached). Outbound transfers went to two wallets opened in February 2026 (also held by students), one bank account at another institution, and one wallet that cashed out the funds at an agent in Accra. Average retention in the wallet was under 4 hours.

Why suspicious. The volume is roughly 30 times the declared level and inconsistent with the customer’s profile; senders are unrelated and three have reported fraud; funds leave almost immediately to newly opened accounts. No legitimate explanation was found in the customer’s records or account history.

Actions. Linked reports filed on the two recipient wallets held with us (refs on file). Account placed under enhanced monitoring per internal policy.

Attachments

Attach what supports the narrative, typically:

• a transaction schedule (date, time, amount, counterparty, channel),
• relevant KYC documents,
• complaint or reversal records,
• a simple flow diagram for complex cases.

Keep these documents on the case as evidence files, and tick the ones that go with the report on its draft. SpeculaPro’s goAML file itself doesn’t carry attachments: after export, the report’s filing package is a ZIP of the exported file, the files you ticked and a list of their fingerprints, so you have everything to hand when you file. The transactions you select on the report are already in the file, so a separate schedule is only needed if the FIC asks for one. Confirm accepted formats and size limits with current goAML guidance.

Before you submit

• Can someone who has never seen the case understand it from the narrative alone?
• Are all amounts in GHS (with original currency where relevant) and do the totals add up?
• Are names, ID numbers and account numbers complete and correct?
• Have you explained why it’s suspicious, not just what happened?
• Is the case closed as Report filed, or will it be once the report is filed? Notes can still be added to a closed case, for example when the FIC asks a question.
• Has a second person approved it?

Never tell the customer

Don’t tell the customer, or anyone outside those who need to know, that a report has been or may be filed. That includes hints such as “your account is under review by compliance because of the FIC”. See Tipping off and confidentiality.

After filing

• Record the FIC’s reference and the submission date on the report, then its answer. See Filing with goAML.
• Keep monitoring the customer; filing a report doesn’t end your obligations.
• If the FIC asks for more information, respond through your MLRO and record it on the case.
• If the activity continues, consider a further report rather than assuming the first one covers it. Follow your MLRO’s guidance.

Related

• Investigating an alert
• Choosing a disposition
• Drafting an STR from a case
• Regulatory reporting
• Roles and permissions