October 27, 2026 · Jurisdiction Briefing

Mauritius: what the FIAML Regulations and the Bank of Mauritius Guideline require on correspondent banking, shell banks and wire transfers

Regulations 16, 17 and 20 of the Financial Intelligence and Anti-Money Laundering Regulations 2018 set the Mauritius rules on correspondent banking, shell banks and wire transfers. The Bank of Mauritius AML/CFT Guideline restates them and adds its own…

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Which texts these are, and whether they are current

The Regulations. The Financial Intelligence and Anti-Money Laundering Regulations 2018 are GN 108/2018, published in Government Gazette No. 88 of 28 September 2018, made under the Financial Intelligence and Anti-Money Laundering Act. They came into operation on 1 October 2018.
The copy used. The text here is the consolidated copy the FIU uploaded to its website on 3 August 2022. It records amendments made by GN No. 122 of 2018 and Act No. 9 of 2019. A search of the FIU’s media library on 26 October 2026 returned no later copy of these Regulations.
The Guideline. The Bank of Mauritius Guideline on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation is dated January
The Bank’s guideline listing shows it under 15 January 2020; the newer entries on that listing (checked 26 October 2026) are on other topics. It came into effect from the date of issue.
Authority. The Bank issued it under, among others, section 18(1)(a) of the FIAML Act, sections 64B and 100 of the Banking Act 2004 and section 40 of the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019.

“Should” in this Guideline is not optional

Paragraph 2.13 of the Guideline settles how to read it: where it uses “shall”, “must” or “should”, the Guideline says, “it is a mandatory requirement”. Several of the wire-transfer and correspondent paragraphs below use “should”. Under 2.13, the Bank treats them as mandatory. The Bank says it will deal with failures to meet the Guideline under its Sanctions Framework, which can mean non-monetary sanctions, monetary penalties and, in very serious cases, revocation of the licence.

Who each text applies to

The two texts do not use the same addressee, and the difference matters for wire transfers.

Regulations 16 and 17 (correspondent banking, shell banks) apply to a reporting person.
Regulation 20 (wire transfers) puts its duties on a relevant person, which regulation 20(16) defines as “a bank or foreign exchange dealer”.
The Guideline applies to “financial institutions”: banks, non-bank deposit taking institutions, cash dealers and money lenders licensed by the Bank under the Banking Act 2004, and licensees under the National Payment Systems Act 2018.

Our reading: a non-bank institution outside “bank or foreign exchange dealer” may fall outside regulation 20 itself, but the Guideline’s own wire-transfer paragraphs (6.184 to 6.194) are addressed to every financial institution in its scope. Check which hat your licence wears before you scope the control.

Correspondent banking: regulation 16

For cross-border correspondent banking “and other similar relationships”, regulation 16(1) requires, in addition to normal CDD, that you:

gather enough information about the respondent to understand fully the nature of its business;
determine from publicly available information its reputation and the quality of its supervision, including whether it has been subject to an ML or TF investigation or regulatory action;
assess its AML/CFT controls;
obtain senior management approval before establishing a new correspondent relationship;
clearly understand and document the respective responsibilities of each institution.

The Regulations define “senior management” as an officer or employee with sufficient knowledge of the institution’s ML/TF risk exposure and sufficient seniority to take decisions on it, who need not, in all cases, be a board member.

Payable-through accounts. Regulation 16(2) adds that you must be satisfied the respondent has performed CDD on its customers with direct access to your accounts, and can provide relevant CDD information on request. “Satisfied” is a defined term: you must be able to justify your assessment to the competent authorities, including the FIU.

What the Guideline adds

Paragraph 6.151 restates the five steps and fills them in:

The information to gather includes the correspondent’s management, major business activities, where it is located, its money-laundering prevention and detection efforts, and the identity of any third party entities that use the correspondent services.
A condition on going ahead. Establish the relationship only if you are satisfied the foreign institution is effectively supervised and has effective customer acceptance and KYC policies.
Documenting responsibilities. The Guideline says the two institutions need not always reduce their responsibilities into written form, provided there is a clear understanding of which one performs the required measures. Regulation 16(1)(e) itself says “document”. Our view: write it down. The regulation is the stricter text, and a written allocation is what you can show an examiner.

Paragraph 6.152 then sets the posture for riskier respondents:

pay particular attention to correspondents in jurisdictions with poor KYC standards, or identified as non-cooperative or as having AML/CFT deficiencies;
establish that correspondents have due diligence standards as set out in the Guideline, and apply enhanced due diligence to the transactions carried out;
where transactions have no apparent economic or visible lawful purpose, examine their background and purpose as far as possible and keep the findings in writing, available to the auditors and to the Bank on request;
keep senior management regularly informed of high-risk correspondent relationships and how they are monitored.

Paragraph 6.153 warns that correspondent services may be used directly by third parties to transact on their own behalf, and says such arrangements should be treated under the Guideline’s criteria for introduced business.

The Guideline’s risk chapter lists, among correspondent-banking risk factors, “limited information about the remitter and source of funds” and “the possibility that PEPs are involved in the ownership of a bank”.

Shell banks: regulation 17

Regulation 17 has two paragraphs:

you shall not enter into or continue a business relationship or occasional transaction with a shell bank; and
you shall take adequate measures to ensure you do not deal with a respondent that permits its accounts to be used by a shell bank.

A shell bank is a bank with no physical presence in the country where it is incorporated and licensed, and which is unaffiliated with a regulated financial group subject to effective consolidated supervision. “Physical presence” means meaningful mind and management located within a country, and it excludes “simply a local agent or low level staff”. The Guideline repeats both duties at paragraphs 6.154 and 6.155.

Wire transfers: regulation 20

What must travel with the payment

Every cross-border wire transfer must always carry:

Originator information, required and accurate: the originator’s name; the account number used, or a unique transaction reference number that permits traceability; and the originator’s address, or national identity number, or customer identification number, or date and place of birth.
Beneficiary information: the beneficiary’s name, and the account number or a unique transaction reference number.

For batch files from a single originator, the file must carry the originator information and full beneficiary information traceable within the beneficiary country, and you must include the originator’s account number or unique reference. For domestic wire transfers, the ordering institution must include the originator information in regulation 20(1).

Regulation 20(5) is the hard stop: the ordering institution shall not execute a wire transfer that does not meet paragraphs (1) to (4).

One wording point to note. Where the Guideline restates regulation 20 at paragraph 6.172, the third originator item reads “and date and place of birth”; the regulation, and the Guideline’s own paragraph 6.186, read “or”. The regulation is the binding text; build to “or”.

The Guideline’s lighter set below USD/EUR 1,000

Paragraph 6.186 provides that cross-border wire transfers of less than USD/EUR 1,000 should be accompanied by the originator’s name and account number (or unique reference), and the beneficiary’s name and account number (or unique reference). That information need not be verified for accuracy, but the institution should verify it where there is a suspicion of ML or TF. Regulation 20 itself, in the FIU’s copy, sets no amount threshold. Our view: while the Regulations carry no threshold, the safer course is to send the full regulation 20(1) set on every cross-border transfer.

Ordering, intermediary and beneficiary institutions

Role	Duty in regulation 20
Ordering	Keep all originator and beneficiary information, in accordance with section 17F of the Act and regulation 14 (20(4)); do not execute a non-compliant transfer (20(5)).
Intermediary	Keep all originator and beneficiary information with the transfer (20(6)); where technical limitations stop it travelling with a related domestic transfer, keep a record of everything received for at least 7 years (20(7)); take reasonable measures, consistent with straight-through processing, to identify transfers lacking required information (20(8)); have risk-based policies on when to execute, reject or suspend such a transfer, and on follow-up (20(9)).
Beneficiary	Take reasonable measures, which may include post-event or real-time monitoring where feasible, to identify transfers lacking required information (20(10)); verify the beneficiary’s identity where not previously verified (20(11)); have risk-based execute, reject or suspend policies and follow-up (20(12)).

Money or value transfer service (MVTS) providers. They must comply with regulation 20 in the countries where they operate, directly or through agents (20(13)). An MVTS provider controlling both the ordering and the beneficiary side must take into account the information from both sides to decide whether an STR has to be filed, file an STR in any country affected, and make the transaction information available to the FIU (20(14)). Regulation 18 separately requires an MVTS provider to keep a list of its agents and sub-agents, available to the FIU or the relevant authority on request, and to include its agents in its AML/CFT programme and monitor them.

What regulation 20 does not cover (20(15)): transfers flowing from a card purchase of goods or services, so long as the card number accompanies all transfers flowing from the transaction; but a card used to make a person-to-person wire transfer is covered. Bank-to-bank transfers and settlements where both parties are financial institutions acting on their own behalf are also outside it.

What the Guideline adds on payment messages

Nominees and agents. Where the originator acts for others (nominee, agent, trustee), the message carries the nominee’s name, address and account, and the paying institution should have on file the name and address of the underlying principals. For a company, the address is its registered office.
No stripping. Institutions should not omit, delete or alter information in payment messages to avoid its detection by another institution in the chain (6.187).
Higher-risk and sanctioned flows. Monitor payment messages to and from higher-risk countries, and suspend or reject messages or transactions with sanctioned parties or jurisdictions (6.188).
Terrorist hits. Where name screening confirms the originator or beneficiary is a terrorist or terrorist entity, the duty to block or reject “cannot be risk-based” (6.189). Positive hits go to the AML/CFT compliance function, and the decision to approve or reject is made at an appropriate level and documented (6.190).
Cover payments. For a cross-border cover payment “regardless of amount” (the Guideline gives MT202COV as an example), the ordering institution’s cover message to the intermediary carries originator and beneficiary information identical to the message sent directly to the beneficiary institution (6.192). The intermediary should check those fields are complete and screen the originator and beneficiary names (6.193).
Incomplete incoming transfers. Apply enhanced scrutiny; request the missing information from the ordering institution; consider rejecting the transfer or terminating relations with ordering institutions that fail to provide it; and treat the gap as a factor in deciding whether to report to the FIU (6.194).

What breach can cost

In the FIU’s copy, regulation 33 makes contravention of the Regulations an offence, punishable on conviction by a fine not exceeding one million rupees and imprisonment for a term not exceeding 5 years. Separately, failure to meet the Guideline is dealt with under the Bank’s Sanctions Framework, as described above.

What this means for an MLRO

Our view: these provisions are where AML meets operations. The correspondent duties sit with relationship and onboarding teams, the wire-transfer duties with payments processing, and both are tested on the message and the file, not on the policy. The Guideline’s paragraph 2.13 removes the comfort of reading “should” as advice.

Seven things worth doing

Map your role per flow. For each payment product, record whether you act as ordering, intermediary or beneficiary institution, and which regulation 20 duties follow.
Test the originator field. Sample outgoing cross-border messages for name, account or unique reference, and one of address, national ID, customer ID, or date and place of birth.
Check the hard stop. Confirm your system will not release an outgoing transfer that fails regulation 20(1) to (4), and that overrides are logged.
Write the incomplete-transfer policy. Set out when you execute, reject or suspend, who decides, how you chase the ordering bank, and when the gap feeds an STR consideration.
Refresh correspondent files. For each respondent, evidence the five regulation 16(1) steps, senior management approval and a written allocation of responsibilities.
Ask the shell-bank question twice. Confirm the respondent is not a shell bank, and that it does not let shell banks use its accounts.
Check cover payments. Confirm MT202COV-type messages you send or pass on carry the same originator and beneficiary data as the underlying transfer, and that you screen those names.

SonarPulse in this jurisdiction: AML/CFT screening software for Mauritius

Sources

This article draws on the following sources. Follow the links for the original text.

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