Suspicious Transaction Reports (STRs)

Suspicious Transaction Reports (STRs)

The reporting of Suspicious Transaction Reports (“STRs”) is one of the most important obligations imposed on subject persons under Malta’s anti-money laundering and counter-terrorist financing (“AML/CFT”) framework. While customer due diligence and ongoing monitoring are designed to prevent financial crime, STRs enable subject persons to alert the Financial Intelligence Analysis Unit (“FIAU”) when suspicious activity is identified.

In simple terms, an STR should be submitted where a subject person knows, suspects, or has reasonable grounds to suspect that funds, transactions or activities may be linked to money laundering, terrorist financing or criminal proceeds. Importantly, a report does not require proof that a crime has occurred. The obligation arises from the existence of suspicion itself.

Recognising Suspicious Activity

Suspicion may arise from customer due diligence findings, transaction monitoring or unusual customer behaviour. Common indicators include, but are not limited to:

• Transactions that are inconsistent with a customer’s known profile;
• Unexplained source of funds or source of wealth concerns;
• Complex or unusual transactions with no apparent economic purpose;
• Reluctance to provide requested information or documentation; and
• Activity involving higher-risk jurisdictions or other recognised risk factors.

While not every red flag will result in an STR, suspicious activity that cannot be reasonably explained should be carefully assessed and, where appropriate, reported.

Reporting Through goAML

The FIAU utilises the goAML platform, developed by the United Nations Office on Drugs and Crime (UNODC), for the submission of suspicious reports. Subject persons must register on the platform before reporting.

The platform facilitates the submission of a range of reports, including Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs), reports relating to politically exposed persons (PEPs), terrorist financing, cash restriction reporting, and other reporting obligations required by the FIAU.

Accurate and comprehensive reporting is essential. The quality of the information submitted can significantly assist the FIAU in analysing the report and determining whether further action is required.

Conclusion

STRs are a cornerstone of Malta’s AML/CFT regime. They enable subject persons to play an active role in identifying and combating financial crime by ensuring that suspicious activities are brought to the attention of the competent authorities. Effective reporting is therefore not merely a regulatory obligation, but a fundamental safeguard that helps protect the integrity of the financial system.

Further Reading

FIAU – Report a Suspicious Transaction
https://fiaumalta.org/what-we-do/report-a-suspicious-transaction/

FIAU Guidance Document on Reporting through goAML
https://fiaumalta.org/app/uploads/2021/02/Guidance-Document-on-Reporting-through-goAML.pdf

FIAU Implementing Procedures Part I (2026)
https://fiaumalta.org/app/uploads/2026/06/Implementing-Procedures-Part-1-2026-1.pdf

Disclaimer: This article is intended for informational purposes only and does not constitute legal, regulatory or compliance advice. Readers should consult the applicable legislation, FIAU guidance and seek professional advice before relying on any information contained herein.