· Jurisdiction Briefing

Qatar: 24 hours or three working days, and how to tell which applies

In Qatar, the deadline for a suspicious transaction report (STR) depends on what you suspect. There are two time limits, and the first decision an MLRO makes is which one applies.

Illustration for “Qatar: the 24-hour clock on a suspicious transaction”

In Qatar, the deadline for a suspicious transaction report (STR) depends on what you suspect. There are two time limits, and the first decision an MLRO makes is which one applies.

The two clocks

The Qatar Financial Information Unit (QFIU) sets them in its Instructions on Implementing Suspicious Transactions Reporting Requirements, April 2024, which supersede the guidance it issued before. A reporting entity must file:

  • within three (3) working days of determining, according to its internal regulations, that it suspects or has reasonable grounds to suspect that a transaction is related to proceeds of crime; and
  • within 24 hours of determining, according to its internal regulations, that the transaction is suspicious and is linked to a terrorist, a terrorist act or a terrorist organisation, or is suspected of being related to high-risk crimes as stated in the National Risk Assessment.

Three details in the text matter in practice.

Non-working days. The instructions exclude the weekend (Friday and Saturday), official regular national holidays and officially declared national holidays from the counting of “the prescribed reporting period”. They do not limit that exclusion to either of the two time limits.

The clock starts at determination. Both limits run from the entity’s determination under its own internal regulations. The instructions note that entities often learn of unusual activity through transaction-monitoring alerts, and require suspicion to rest on both objective and subjective factors.

The suspicion date is on the record. The entity must state the suspicion date in the “Details of the Suspicious Activity” part of the report, and the instructions add that this is subject to the supervision of the relevant supervisory authorities.

There is no monetary threshold. Article 21 of the AML/CFT Law (Law No. 20 of 2019) requires reports on transactions, including attempted ones, regardless of their value.

What that does to your operating model

In our view, a 24-hour limit, even a narrow one, asks for three things a multi-day limit does not:

  • An authorised filer who is always reachable. The QFIU accepts STRs only from the approved MLRO or Deputy MLRO, each registered with the QFIU after approval by the entity’s supervisory authority. Plan cover for weekends and holidays too.
  • Triage that classifies early. Recognising a suspicion as terrorism-linked or related to a high-risk crime in the National Risk Assessment is what brings the shorter limit into play, so that call belongs at the start of a case.
  • A report that is ready to file. The QFIU confirms that each STR meets its formal and objective criteria and was filed on time by the authorised officer. If it asks for more information, the entity has five (5) days from the notification to provide it, and the QFIU may reject the report if it does not.

Who does what

The QFIU is operationally independent. Law No. 18 of 2025, which rewrote Article 31 of the AML/CFT Law, gives it its own legal personality and has its Head appointed by the Governor of Qatar Central Bank. It receives and analyses STRs, disseminates the results to competent authorities, and issues reporting instructions in coordination with the supervisors. It joined the Egmont Group in 2005. The National Anti-Money Laundering and Terrorism Financing Committee (NAMLC), formed at the QCB and chaired by the Governor, coordinates the national risk assessment and develops the national AML/CFT strategy.

Supervision is allocated by Article 59 of the Implementing Regulations (Council of Ministers’ Decision No. 41 of 2019):

Supervisory authoritySector
Qatar Central BankBanks and exchange houses; money or value transfer service providers; insurance and reinsurance; finance and investment companies
Qatar Financial Markets AuthorityFinancial brokerage firms and intermediaries; Qatar Stock Exchange; Qatar Central Securities Depository
Ministry of JusticeLawyers; notaries; real estate agents
Ministry of Commerce and IndustryLegal accountants; traders in precious metals and stones; trust and company service providers
QFC Regulatory AuthorityFinancial institutions and DNFBPs established in the Qatar Financial Centre
Regulatory Authority for Charitable ActivitiesNon-profit organisations

Article 59 also includes any other competent authority empowered by law to regulate, supervise or monitor these entities.

For groups with entities inside and outside the QFC, the split is worth mapping. The QFCRA says firms operating in or from the QFC are subject to Qatar State legislation and the QFC AML/CFT Rules. Whatever the supervisor, the Article 21 duty is to report to the QFIU.

Three things worth doing this week

  1. Decide where the classification happens. Write down who decides that a case is terrorism-linked or high-risk-crime related, and at what point. That determination is what starts the clock.
  2. Time your own pipeline. Take the last ten STRs you filed and measure the gap between the suspicion date you recorded and the submission date.
  3. Check your cover for the next public holiday. Confirm that an approved MLRO or Deputy MLRO can file that day. Until the QFIU confirms how the non-working-day exclusion applies to a limit counted in hours, the cautious plan is to assume it does not pause the 24-hour clock.

Sources

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

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