A Suspicious Transaction is defined under the FIAMLA as a transaction which:

(a) gives rise to a reasonable suspicion that it may involve:

(i) the laundering of money or the proceeds of any crime; or

(ii) funds linked or related to, or to be used for, the financing of terrorism or proliferation financing or, any other activities or transaction related to terrorism as specified in the Prevention of Terrorism Act or under any other enactment, whether or not the funds represent the proceeds of a crime;

(b) is made in circumstances of unusual or unjustified complexity;

(c) appears to have no economic justification or lawful objective;

(d)is made by or on behalf of a person whose identity has not been established to the satisfaction of the person with whom the transaction is made; or

(e) gives rise to suspicion for any other reason.

You are encouraged to submit a STR as soon as possible but not later than 5 working days after the suspicion arose. The 5 working days exclude Saturdays, Sundays and Public holidays and run from the time the suspicion is formed.

Failure to report STRs is a criminal offence and on conviction, Reporting persons are liable to a fine not exceeding 1 million rupees and to imprisonment for a term not exceeding 5 years.

The Money Laundering Reporting Officer (MLRO)/Deputy Money Laundering Reporting Officer (DMLRO) appointed in line with Regulation 26 of the FIAMLR 2018 is responsible to assess internal suspicious transaction report and file STRs to the FIU.

Where a reporting person is unable to appoint a MLRO due to the size or nature of its business or activity, then the reporting person (sole director) himself/herself should act as the MLRO and should establish, maintain and operate reporting and disclosure procedures.

The outsourcing of MLROs is not permitted by our laws.

The duties and responsibilities of the MLRO are to, amongst others,

• Ensure that any internal disclosures of suspicious transactions are made to him;
• Consider any information available for determining whether or not it gives rise to any knowledge or suspicion of ML/TF;
• Determine if there are grounds to submit a Suspicious Transaction Report (STR) to the FIU;
• Act as a key liaison point with the FIU and other law enforcement authorities;
• Have unrestricted access to information that may be of assistance in the discharge of his/her duties;
• File Suspicious Transactions Reports (STR) to the FIU;
• Have direct access to the board of directors of the reporting person.

A suspicious transaction report (STR) should be submitted to the FIU electronically through the goAML platform. In exceptional cases, manual STR can be filed using the prescribed form. (Contact goAML helpdesk for assistance)

You can refer to the goAML Web User Guide, the Guidance Note 4-Suspicious Transaction Report,  the goAML User Guide (STR Scenarios) 2019 and video tutorials on the GoAML platform for the filing of STR.

Every reporting person who has an obligation to make a report to the FIU under section 14 of the FIAMLA 2002, shall  register on the goAML Platform.

Each reporting person will register its organisation only once on the goAML Platform, unless the registration was rejected.

The Reporting Persons must select “Register as Organisation” from the goAML Home page.

Please refer to Section 1.2 of the goAML Web User’s Guide: Chapter 1 – Registration (available on goAML Home page).

A user (other than the MLRO/ Admin) can register on goAML only after the registration of its organisation has been activated by its Supervisory Body.

The user must select “Register as Person” from the goAML Home page and register with the correct Organisation ID.

Please refer to Section 1.3 of the goAML Web User’s Guide: Chapter 1 – Registration (available on goAML Home page)

This is the Tax Account Number (TAN) number of the organisation.

In this case, in addition to follow up with the supervisory body, the Reporting institution shall seek the assistance of the FIU’s goAML Helpdesk by email (goamlhelpdesk@fiumauritius.org).

In this case, the new MLRO is requested to follow the below steps:

1. Inform the FIU’s goAML Helpdesk via a letter or email that:

               (i) he/she is the new MLRO of the organisation;

               (ii) no handing over was done by former MLRO; and

               (iii) there is no admin user for their organisation.

2. Register himself/herself as a user under his/her organisation (with the correct Organisation ID) and attach a letter (with the information under 1. above) along with a copy of NIC or passport.
3. Any assistance, contact goAml helpdesk. (goamlhelpdesk@fiumauritius.org)

Reporting persons are however reminded that, to prevent such continuity issues, they are strongly recommended to put in place proper handing over procedures for all their users linked to their goAML accounts.

Once an STR is submitted, the user will receive a notification (through the email registered for the Organisation) that a report has been submitted. Any acceptance or rejection, a notification will be sent on your registered email.

As per section 16 (1) FIAMLA, Tipping off is the act of disclosing to any person that a suspicious transaction report is being or has been filed, or that related information is being or has been requested by, furnished or submitted to FIU.

Tipping off is a criminal offence and on conviction Reporting persons are liable to a fine not exceeding 5 million rupees and to imprisonment for a term not exceeding 10 years.