Mauritius: the FIU clarifies when the five-working-day STR clock starts
Section 14(1) of the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) requires every reporting person or auditor, as soon as he becomes aware of a suspicious transaction, to make a report to the FIU "promptly but not later than 5 working…
Section 14(1) of the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) requires every reporting person or auditor, as soon as he becomes aware of a suspicious transaction, to make a report to the FIU “promptly but not later than 5 working days after the suspicion arose”. The FIU has now put in writing which moment starts that count. It says so because it recognised that certain aspects of the section 14 obligation — the meaning of reporting promptly, when the five working days commence, and what the MLRO or deputy MLRO must do on receiving an internal report — could be read in different ways.
In August 2026 the FIU published Suspicious Transaction Reporting Guidance Note 4.1 — Supplementary Guidance on the STR Reporting Process, which came into effect on 19 August 2026. It is issued under section 10(2)(c)(i) of FIAMLA, and applies to every person designated as a reporting person under section 2 of FIAMLA.
Read the first two pages before anything else. The FIU is explicit that Guidance Note 4.1 is to be read together with the earlier STR Guidance Note 4 and does not replace, revoke or otherwise amend it, and that it creates no new legal obligations. Where the Guidance Note and the legislation are inconsistent, FIAMLA and the FIAML Regulations prevail. Nothing below is a change in the law. It is the FIU writing down how it reads a duty that already exists — which, for a supervised firm, is the part that decides whether a file looks late.
The clock starts at the determination, not at the escalation
The core paragraph is in section 7.3:
> “the five (5) working days period for submission of a STR to the FIU shall > commence when the MLRO/DMLRO determines, following a reasonable preliminary > assessment, that reasonable grounds for suspicion exist.”
The FIU adds that the date on which the internal STR reaches the MLRO or deputy MLRO does not, by itself, start the period. The statutory period begins once the preliminary assessment is complete and the conclusion has been reached that reasonable grounds for suspicion exist.
That reads like breathing room. It is not, because the same paragraph closes the door behind it. The FIU says the principle must not be read as allowing a reporting person or an MLRO to delay the start of the statutory period by running unnecessarily lengthy assessments or reviews, and that the preliminary assessment must be completed within a reasonable timeframe having regard to the circumstances of the case. In other words, the assessment window is not part of the five days, but it is not unlimited either — and it is now something a supervisor can ask you to justify.
What “promptly” means
Section 7.1 gives the FIU’s interpretation of the word in section 14(1). “Promptly” means acting without unnecessary or avoidable delay once reasonable grounds for suspicion have been established. Where the MLRO or deputy MLRO determines that reasonable grounds exist, the FIU’s expectation is that the STR is submitted the same day where reasonably practicable.
The FIU accepts that in more complex cases, same-day compilation and submission may be challenging given the volume or complexity of the information and documentation involved. In those cases the STR must go in within the shortest time possible and in no case later than five working days. One sentence is worth pinning to the wall: the FIU states that delays in submitting STRs occasioned by a lack of human or IT resources are not considered acceptable.
The key-requirements table in section 4 makes the same point from the other side. Five working days is the maximum time permitted by law and should not be treated as the expected reporting timeframe.
Multi-layer internal sign-off is now called out by name
Section 6.1 deals with the internal leg, and it is the part that may send you back to your procedure manual. The FIU says internal arrangements should let any employee, including those who review automated monitoring alerts, raise an internal STR directly to the MLRO or deputy MLRO, and that internal procedures should not require mandatory supervisory or management approvals before an internal STR reaches the MLRO/DMLRO. Reporting persons should avoid processes that route a matter through multiple levels of management first, because excessive internal escalation delays assessment and can affect the firm’s ability to meet its statutory obligation.
The workflow table in section 3.2 says the same thing at step 2: the internal report goes directly and immediately to the MLRO or deputy MLRO, and staff should not delay escalation to investigate further. It lists what the internal report should contain — the identity of the customer and any related parties; the nature, value and timing of the activity; the reasons for suspicion; and any supporting documents or transaction records — and says the list is not exhaustive. At step 3, the MLRO immediately records receipt of the internal STR, including the date and time.
Section 6.2 turns this into a documented control. Reporting persons shall establish and maintain documented policies, procedures and controls for handling internal STRs and the MLRO’s preliminary assessment. Those policies should be approved by senior management and should set a reasonable timeframe within which the MLRO is expected to review and assess internal STRs. The FIU lists seven factors to set it against: the nature, size and complexity of the organisation; the volume and frequency of internal STRs; the availability of relevant information; the complexity of the transactions or activities under review; the resources available to the MLRO function; the risk profile of the customer or activity; and the potential consequences of delayed reporting. Section 7.4 adds that where a matter involves heightened risks, the assessment should be done in a shorter timeframe than the ordinary one — the same clock for every case is not a risk-based approach.
Two things that are not the five-day track
TF and PF are carved out. Where reasonable grounds to suspect terrorist financing or proliferation financing have been established, the FIU says the STR should be submitted immediately, and that the MLRO should not hold it back to gather further information that is not needed to support the reporting decision. A footnote ties “immediately” to the meaning given in section 2 of the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019.
A goAML rejection does not buy you time. Section 7.2 says a rejection should not be read as a determination that the underlying transaction or activity is not suspicious, and does not relieve the reporting person of its obligations under section 14. The required information must be corrected, supplemented or clarified and the STR resubmitted without unnecessary delay — and a reporting person should not treat a rejection as extending or resetting the statutory period. Keep records of the original submission, the FIU notification or rejection, the corrective action and the date of resubmission. Where relevant information turns up after filing, the FIU points to the goAML message board, quoting the Report Key of the STR.
Three clocks, and they are not the same clock
FIAMLA sets three separate time limits in this area. Only one of them is the reporting deadline.
| Clock | Provision | What it measures |
|---|---|---|
| 5 working days | s.14(1) FIAMLA | The outer limit for submitting an STR after the suspicion arose. Guidance Note 4.1 states that it commences when the MLRO determines that reasonable grounds for suspicion exist. |
| Not exceeding 72 hours | s.10A(2) FIAMLA | How long the FIU may order you to temporarily suspend a suspicious transaction. Extended to not more than 120 hours where the deadline falls on a Sunday, a public holiday or an FIU non-working day, and a Judge may extend it further. |
| 24 hours | s.10A(5) FIAMLA | How long you have to furnish additional information the FIU requests on a temporarily suspended transaction. |
Section 10A was added to FIAMLA by Act No. 3 of 2026 with effect from 18 April
- It governs a suspension the FIU orders. It has nothing to do with when your
reporting clock started.
What it costs to get it wrong
Guidance Note 4.1 sets out the penalties in section 8.
| Offence | Provision | Penalty |
|---|---|---|
| Failure to file an STR within 5 working days | s.14(3) FIAMLA | Fine not exceeding MUR 1,000,000 and/or imprisonment up to 5 years |
| Tipping off — disclosing that an STR has been or is being filed | s.16(3)(A) FIAMLA | Fine not exceeding MUR 5,000,000 and/or imprisonment up to 10 years |
| Failure to comply with AML/CFT obligations (administrative) | s.19H(1)(d)(iii) FIAMLA; FIAML (Administrative Penalties) Regulations 2025 | Administrative penalties from MUR 5,000 up to MUR 250,000 per breach, depending on gravity |
Section 14(3) of FIAMLA reaches further than a missed date. It catches a reporting person or auditor who becomes aware of a suspicious transaction or ought reasonably to have become aware of one and fails to report within the five working days.
Three things worth doing
- Read your escalation procedure for approval gates. If an internal STR has to be signed by a line manager, a head of department or a committee before it reaches the MLRO, section 6.1 is pointed at you. Strip the gate out, and make sure the alert reviewers know they can raise directly.
- Put the assessment timeframe in writing and take it to senior management. Section 6.2 asks for a documented, senior-management-approved timeframe built against those seven factors, with a shorter one for higher-risk matters. Without it, a reasonable preliminary assessment is whatever the file happens to look like after the fact.
- Record four dates on every STR, not one. The date the internal report was received, the date the assessment began, the date the MLRO determined that reasonable grounds existed, and the date of submission. Section 7.5 lists these among the records to maintain, and after Guidance Note 4.1 the third date is the one the five working days are counted from. Keep the STR and its supporting documentation for at least seven years from the date of the report.
Sources
This article draws on the following sources. Follow the links for the original text.
- Financial Intelligence Unit (Mauritius) — Suspicious Transaction Reporting Guidance Note 4.1: Supplementary Guidance on the STR Reporting Process, August 2026
- Financial Intelligence Unit (Mauritius) — The Financial Intelligence and Anti-Money Laundering Act 2002 (consolidated, updated 2026)
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