Suspicious Transaction Reports in Mauritius

What a suspicious transaction report is

A suspicious transaction report mauritius businesses file is a confidential notice sent to the Financial Intelligence Unit (FIU). It tells the FIU that a transaction, or an attempted one, gives rise to a suspicion of money laundering, terrorist financing or proliferation financing. The duty comes from the Financial Intelligence and Anti-Money Laundering Act (FIAMLA), and it sits at the centre of the wider AML/CFT framework for Mauritian companies.

An STR is not an accusation and not proof of wrongdoing. It is a flag raised by the person who sees the facts first: the firm handling the client, the account or the payment. The FIU analyses the report and decides what to do with it. The reporter does not investigate, and does not need to be certain.

The reporting duty falls on a "reporting person", and the FIAMLA also places it on auditors. Whether your company counts as a reporting person depends on its activity, so check that point with an adviser before assuming either way. If you are unsure of the vocabulary, the glossary defines the main terms.

When you must report

The FIAMLA requires a reporting person or auditor to report a suspicious transaction to the FIU as soon as they become aware of it, and no later than 5 working days after the suspicion arose (section 14, consolidated text 2026). "As soon as possible" is the rule; the 5 working days are the outer limit, not a target.

Three practical points follow from that wording.

• The clock runs from suspicion, not from proof. Waiting for confirmation before filing is the most common way to miss the deadline.
• Attempts count in practice. A client who abandons a transaction after being asked for documents can still be the subject of a report, since the suspicion exists regardless of completion. Ask your adviser how this applies to your sector.
• Internal escalation must be fast. A suspicion noticed by an accountant or an administrator is useless if it sits in an inbox for a week.

Signs that often prompt a report

The law does not give a closed list, and no single sign decides the matter. Typical triggers include:

• a transaction with no clear commercial purpose;
• a client who is evasive about who owns or controls a company, which ties directly to the beneficial ownership register;
• funds whose origin the client cannot or will not explain, see source of funds and source of wealth;
• a counterparty linked to a jurisdiction the authorities treat as high risk;
• a client who asks you to avoid the usual records or reports.

Under section 17H of the FIAMLA, the Minister may designate as high-risk a jurisdiction identified by the FATF as having strategic deficiencies, on the recommendation of the National Committee. Enhanced due diligence then applies to transactions involving that country. Background is in Mauritius and the FATF grey list.

How to file

Reports go to the FIU, and the practical route is the FIU's electronic reporting platform. Registration and use are explained in registering with the FIU and using goAML. A short outline of the workflow:

The internal decision usually belongs to the compliance function. The appointment and role of that officer are covered on the MLRO page; this page deals only with what happens once a suspicion exists.

What a good report contains

A useful report is factual and complete. Include who the parties are, what happened, the amounts and dates involved, the accounts or assets concerned and, above all, the reasons for the suspicion. Attach or reference supporting documents, such as the client's identification and the transaction records. Avoid conclusions you cannot support; describe facts and explain why they looked inconsistent with the client's known profile.

Do not tip off the client

Telling a third party that an STR is being, or has been, filed is called tipping off. It is an offence under the FIAMLA. On conviction, the penalty is a fine of up to Rs 5 million and imprisonment of up to 10 years. The text includes an exception for compliance exchanges within a group, provided confidentiality safeguards are in place (consolidated text 2026).

In day-to-day work, this means:

• do not tell the client, or anyone connected to the client, that you have reported or are considering a report;
• limit knowledge of the report to those who need it;
• if you must decline or pause a transaction, give a neutral reason that does not reveal the suspicion;
• keep the report out of ordinary client files and shared folders.

The difficulty arises when a client keeps pressing for a transaction to go ahead. Delay can itself look suspicious. Staff need a script for these moments, and the policy should say who handles the conversation.

Penalties for getting it wrong

Failure to report in time is an offence under section 14(3) of the FIAMLA. On conviction the maximum is a fine of Rs 1 million and imprisonment of up to 5 years. A separate provision covers a reporting person, or its officer, employee or agent, who knowingly or without reasonable excuse breaches sections 17 to 17G, destroys a required record or facilitates a transaction under a false identity: the maximum is a fine of Rs 10 million and imprisonment of up to 5 years.

These are statutory maxima on conviction. They are not predictions of what a court would impose. For the wider picture, including supervisory consequences, see penalties for failing anti-money laundering duties.

STRs and cash transaction reports are different

Do not confuse an STR with the cash transaction report. Section 17G of the FIAMLA requires a reporting person to send the FIU, in the prescribed time and form, a report on any cash transaction reaching the prescribed amount, including linked transactions. That duty is triggered by size, not by suspicion; an STR is triggered by suspicion, whatever the amount. A single transaction can require both.

What to keep, and for how long

Reporting does not end the paperwork. Under section 17F of the FIAMLA:

• customer due diligence records, including identity documents of customers and beneficial owners, are kept for at least 7 years after the end of the business relationship;
• transaction records are kept for 7 years after the transaction;
• copies of suspicion reports are kept for at least 7 years after filing.

General retention rules for company records are in company records: what to keep. Keep the STR copy and your reasoning together, and restrict access, so that the tipping-off rule is respected even inside the firm.

The 2026 amendments

Act No. 3 of 2026 amended Part IV of the FIAMLA, which covers the measures against money laundering, terrorist financing and proliferation financing, with effect from 18 April 2026. The amendments touch, among other things, the obligation to report suspicious transactions and the risk assessment. Section 17, as amended, requires each reporting person to identify, assess and understand its money laundering, terrorist financing and proliferation financing risks, across clients, geographic areas, products, services, transactions and delivery channels, and to set its mitigation measures accordingly.

That is why the quality of your business risk assessment matters for reporting: it tells staff what "normal" looks like for your clients, so that deviations are noticed. Customer due diligence also applies on opening an account or business relationship and, for an occasional customer, from a transaction of Rs 500 000 or the foreign currency equivalent (or the prescribed amount), alone or linked, and for any domestic or cross-border wire transfer (section 17C). The practical side is in the KYC checklist for corporate clients.

Building a reporting routine

A small company does not need a heavy system, but it does need a written one. Consider the following checklist:

• A written procedure says how staff escalate a concern, and to whom
• Staff have been trained to recognise unusual activity and to avoid tipping off
• The person who decides on reports has a deputy for absences
• The company is registered on the FIU's reporting platform before it needs it
• Each decision, including a decision not to report, is recorded with reasons
• Report copies are stored separately, with limited access, for at least 7 years
• Training and the programme are reviewed, see AML/CFT training and independent audit

If your company relies on an outside provider for administration, ask in writing how the provider escalates suspicions and what it will tell you. A provider may be under a duty not to inform you about a report it files. Our guidance on choosing a corporate services provider lists points worth raising before you sign.