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STOR, STR, SAR & SMR: the reporting terms, explained

When a surveillance analyst concludes that activity is genuinely suspicious, the next step is a report to the authorities. What that report is called, and who receives it, depends entirely on the jurisdiction. Getting the terminology right is a basic professional discipline.

REPORTING · ~5 MIN READ

These acronyms are not interchangeable, and using the wrong one is a tell-tale sign of someone who has not worked across jurisdictions. Each refers to a distinct report, defined in a distinct regime, filed with a distinct authority. Here is the map.

The five regimes at a glance

TermJurisdictionFull nameFiled with
STORUK / EUSuspicious Transaction and Order ReportFCA
SARUSSuspicious Activity ReportFinCEN
STRSingaporeSuspicious Transaction ReportSTRO
STRHong KongSuspicious Transaction ReportJFIU
SMRAustraliaSuspicious Matter ReportAUSTRAC
ASIC SARAustraliaSuspicious Activity Report (market abuse)ASIC

STOR: United Kingdom and EU

In the UK and across the EU, the market-abuse report is the Suspicious Transaction and Order Report. The word Order is doing real work here. The regime expects firms to report suspicious orders, not only executed transactions, which is precisely why order-based manipulation such as spoofing and layering sits squarely within its scope. UK STORs go to the Financial Conduct Authority.

SAR: United States

The US operates a unified Suspicious Activity Report filed with the Financial Crimes Enforcement Network (FinCEN). Unlike the UK’s dedicated market-abuse report, the US SAR carries both anti-money-laundering and market-abuse concerns in a single instrument.

STR: Singapore and Hong Kong

Both Singapore and Hong Kong use the term Suspicious Transaction Report, but they go to different bodies. In Singapore, the STR is filed with the Suspicious Transaction Reporting Office (STRO); in Hong Kong, with the Joint Financial Intelligence Unit (JFIU). Same acronym, two regimes. One more reason precision matters.

SMR and ASIC SAR: Australia’s dual system

Australia is the one that catches people out, because it has two separate reports for two separate purposes. The Suspicious Matter Report (SMR) is the anti-money-laundering report, filed with AUSTRAC. Market-abuse concerns are reported separately as an ASIC SAR to the Australian Securities and Investments Commission. They are distinct reports filed with distinct agencies, and conflating them is a common error.

Why the distinction matters in practice

Beyond looking competent, getting the regime right shapes the whole filing decision: what threshold of suspicion applies, what timeframe you have, what must go in the narrative, and which authority you answer to. A surveillance analyst working a multi-jurisdiction book has to keep all of these straight, and a defensible filing decision depends on it.

The full course

The filing decision, across six jurisdictions

The course covers the suspicious-reporting regimes in depth, across all six jurisdictions: thresholds, timeframes, narrative standards, and the anatomy of a defensible filing.

See the syllabus