Where the regulated person is not able to complete required CDD measures, account shall not be opened or existing business relationship shall be terminated and consideration shall be given if the circumstances are suspicious to warrant the filing of an STR in relation to the customer. The basis of deciding whether an STR is to be filed or not shall be documented and kept on record together with all internal findings and analysis done in relation to a suspicion irrespective of the fact that the transaction is subsequently reported or not. (Section 14(6) of the SECP AML/CFT Regulations, 2018).