Submitting a complaint about disadvantages due to a suspicious activity report or internal report

If there are facts indicating that

1. an asset associated with a business relationship, brokerage or transaction originates from a criminal offense that could constitute a predicate offense to money laundering
2. a business transaction, a transaction or an asset is related to terrorist financing, or
3. the contracting party has not fulfilled its obligation to disclose to the obliged entity whether it intends to establish, continue or carry out the business relationship or transaction for a beneficial owner,

the obliged entity must immediately report this fact to the Financial Intelligence Unit (FIU), irrespective of the value of the asset concerned or the amount of the transaction.

If you are exposed to a disadvantage in connection with your employment relationship due to the submission of a suspicious activity report to the FIU or due to the internal reporting of such facts to the obliged entity, you have the right to lodge a complaint with the competent supervisory authority.

Legal action remains unaffected by the complaints procedure. The complaint is made via a protected communication channel.

Requirements

• You have submitted a suspicious activity report to the FIU or an internal report of suspicious circumstances to your employer.
• As a result of this report, you are at a disadvantage in connection with your employment relationship.