There may be instances when the LFI encounters potentially unusual or suspicious activity that is of a “complex” nature. The following is a non-exhaustive list of factors that should be considered to determine whether investigated activity qualifies as a complex investigation: employee-related investigations; significant investigations involving multiple customers, multiple jurisdictions, multiple accounts, multiple transactions, and/or multiple subpoena requests; and legal referred investigations.

If the LFI designates an investigation as “complex”, the LFI should submit an initial STR or SAR to the FIU within 15 business days of the alert generation. The initial STR/SAR should be labelled as a “Complex investigation” to the FIU. Following the initial STR or SAR filing, the LFI has an additional 30 business days to obtain all necessary information related to the complex investigation and submit a follow-up STR or SAR to the FIU.