The Financial Intelligence Unit (FIU) is pleased to share a Supplementary Guidance on the Suspicious Transaction Reporting Process, STR Guidance Note 4.1.
The Guidance Note has been developed to provide further clarity and practical guidance on the suspicious transaction reporting process, particularly in relation to the identification and escalation of suspicious matters, the role of the MLRO, the internal assessment process, and the requirement to report suspicious transactions promptly under Section 14 of the Financial Intelligence and Anti-Money Laundering Act (FIAMLA).
The FIU recognises the important role that Reporting Persons and their Money Laundering Reporting Officers (MLROs) play in the effective functioning of the suspicious transaction reporting framework. The FIU hopes that this supplementary guidance shall assist Reporting Persons in strengthening their internal arrangements and promote a common and consistent understanding of the reporting process, while facilitating the timely submission of STRs to the FIU.
We would like to clarify that this Supplementary Guidance Note does not replace, repeal, revoke or otherwise amend STR Guidance Note 4 previously issued by the FIU. STR Guidance Note 4 remains applicable and should continue to be read together with this Supplementary Guidance Note, which provides additional clarification on the matters addressed therein.
The Guidance Note shall come into effect as from 19 August 2026 and does not create any new or separate legal obligation for Reporting Persons. Rather, it is intended to assist Reporting Persons in understanding and meeting their existing obligations under FIAMLA and other applicable legal and regulatory requirements. As always, where there is any inconsistency between the Guidance Note and the applicable legislation, the provisions of the legislation shall prevail.
The FIU values the continued cooperation and engagement of Reporting Persons and looks forward to working closely with all stakeholders to further strengthen the suspicious transaction reporting framework.