STR deadlines across the six: two count days, four use words
Every jurisdiction in this series requires a suspicious transaction report. Two of the six put a number on the deadline. The other four use words: promptly and directly in Saudi Arabia, without delay and directly under UAE federal law, which is what firms in…
Every jurisdiction in this series requires a suspicious transaction report. Two of the six put a number on the deadline. The other four use words: promptly and directly in Saudi Arabia, without delay and directly under UAE federal law, which is what firms in DIFC and ADGM file under, and immédiatement in Morocco.
Mauritius counts working days. Section 14(1) of the Financial Intelligence and Anti-Money Laundering Act (FIAMLA) requires a report to the FIU “promptly but not later than 5 working days after the suspicion arose”. The FIU’s FAQs add that the five days exclude Saturdays, Sundays and public holidays, and run from the time the suspicion is formed.
Qatar runs two clocks. The QFIU’s April 2024 instructions require an STR within three working days of determining a suspicion that a transaction is related to proceeds of crime, and within 24 hours where the transaction is suspected of being linked to a terrorist, a terrorist act or a terrorist organisation, or to high-risk crimes named in the National Risk Assessment. The instructions exclude non-working days (the Friday and Saturday weekend and official national holidays) from the counting of “the prescribed reporting period”, without limiting that exclusion to either track.
Who receives it, and how
| Jurisdiction | Deadline wording | Receives it | Channel |
|---|---|---|---|
| Mauritius | Promptly, not later than 5 working days after the suspicion arose (FIAMLA s.14(1)) | FIU Mauritius | goAML; a manual form only in exceptional cases |
| Saudi Arabia | Promptly and directly (AML Law, Art. 15) | General Directorate of Financial Intelligence (SAFIU) | The Directorate’s electronic reporting, first phase launched in 2019 |
| Qatar | 3 working days for proceeds of crime; 24 hours for terrorism-linked or NRA high-risk-crime suspicions (QFIU Instructions, April 2024) | QFIU | QFIU E-STR; a paper form in a sealed envelope if not connected to E-STR, or in urgent cases |
| DIFC | Federal: without delay and directly (Decree-Law 10/2025, Art. 18) | UAE FIU | goAML |
| ADGM | Federal: as for DIFC | UAE FIU | goAML |
| Morocco | Immédiatement (Law 43-05, Art. 9) | ANRF | goAML, the declaration form by email, or another means agreed with the ANRF |
Two patterns stand out.
The UAE’s financial centres add process, not a number. Firms in both file with the UAE FIU under federal AML legislation. DFSA rule AML 13.3.1 requires the MLRO, without delay, to inquire into and document the internal notification, determine and document whether a report must be made, make it if required, and notify the DFSA immediately after submitting it to the FIU. In ADGM, FSRA rule AML 14.3.1 also puts the MLRO’s investigation and determination under a without-delay duty, and asks for the report itself as soon as practicable.
Every one of the six prohibits tipping off.
- Mauritius: FIAMLA s.16(1) bars disclosing that an STR is being or has been filed. Breach carries a fine of up to Rs 5 million and imprisonment of up to 10 years (s.16(3A)).
- Qatar: Law No. 20 of 2019 punishes disclosing information that may reveal whether an STR has been submitted with up to three years’ imprisonment and a fine of up to QR 500,000, or either. The QFIU’s instructions list the offence as Article 84.
- UAE, including DIFC and ADGM firms: Article 29 of Decree-Law 10/2025 punishes warning another person or disclosing information about suspicious transactions under review with imprisonment and a fine of at least AED 50,000, or either.
- Saudi Arabia: Article 16 of the AML Law prohibits disclosing to a customer or anyone else that a report “will be, is being or has been” submitted.
- Morocco: under Article 29 of Law 43-05, officers or agents who knowingly reveal a report, or its follow-up, to the person concerned or to third parties face the penalties of Article 446 of the Penal Code.
The failure mode
In each of these texts, the duty attaches to the suspicion, not to the MLRO’s signature. Mauritius counts from when the suspicion arose. Qatar counts from the determination. The UAE and Saudi duties arise when the institution suspects.
Picture an alert that sits in a queue for nine days, takes two days to analyse, and is filed the same afternoon the MLRO decides. The filing was fast. Whether the report was on time is a different question. In Mauritius, the failure-to-report offence in section 14(3) also covers a reporting person who ought reasonably to have become aware of the suspicious transaction. In Qatar, the instructions require the suspicion date to be stated in the report, and supervisors check it.
That is why the DIFC and ADGM rules are worth studying even outside the UAE. They put the without-delay duty on the MLRO’s inquiry, not just on the filing.
Three things worth doing this week
- Measure alert-to-decision, not only decision-to-filing. Take your last 20 STRs and time each one from first alert to determination, then from determination to filing.
- Write down what the words mean for you. Set an internal target, in hours or days, for promptly, without delay and immédiatement. In Mauritius, count working days from when the suspicion is formed. In Qatar, decide at determination which of the two tracks applies.
- Check who can file, before you need to. The QFIU accepts STRs only from the approved MLRO or Deputy MLRO. Morocco’s Law 43-05 requires firms to give the ANRF the identity of the officers authorised to file, and the Office des Changes’ guide for currency exchange companies says that designation must come before any report. ADGM firms must register on goAML when they receive their permission. A lapsed designation or an expired login is a late report waiting to happen.
However the six word their deadlines, the part a firm controls is the time between the alert and the decision.
Sources
This article draws on the following sources. Follow the links for the original text.
- FIU Mauritius — The Financial Intelligence and Anti-Money Laundering Act 2002 (consolidated, updated 2026)
- FIU Mauritius — Report a Suspicious Transaction
- FIU Mauritius — FAQs: Suspicious Transaction Report and MLRO
- SAMA Rulebook — Anti-Money Laundering Law (Royal Decree No. M/20)
- SAMA Rulebook — The Electronic Report Approved by the SAFIU (circular 606670000067)
- QFIU — Instructions on Implementing Suspicious Transactions Reporting Requirements, April 2024
- QFCRA — Law No. (20) of 2019 on Combating Money Laundering and Terrorism Financing (unofficial English translation)
- CBUAE Rulebook — Federal Decree by Law No. (10) of 2025 on AML/CFT/CPF
- UAE FIU — Compliance & Guidance (goAML)
- DFSA Rulebook — AML 13.3.1, Suspicious Activity Report
- FSRA — Anti-Money Laundering and Sanctions Rulebook (AML) VER11.210526
- Office des Changes — Loi n° 43-05 relative à la lutte contre le blanchiment de capitaux (version consolidée, septembre 2021)
- Office des Changes — Le Guide de la Déclaration de Soupçon pour les Sociétés de Change de Devises (December 2021)
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