C805 - MOKAS’ Annual Sectorial Quantity & Quality Assessment of STRs/SARs submitted to the FIU by Obliged Entities for the year 2025

The report is designed as a risk-intelligence tool, helping firms focus on prevailing high-risk typologies. MOKAS identified the most common suspicion triggers for 2025 as virtual asset-related transactions, money mules, transactions between unrelated counterparties, internet/cyber fraud, and money laundering. For compliance teams, this is a clear supervisory signal to test whether existing AML/CFT frameworks detect these patterns.

Firms should map the indicators to their customer base, products, and transaction flows, then assess whether monitoring scenarios, thresholds, and due diligence processes remain fit for purpose. Where virtual assets, third-party intermediaries, or unusual counterparty relationships feature, enhanced scrutiny and, where necessary, timely STR/SAR submissions are expected. The circular does not introduce new rules, but it underscores the regulator’s focus on reporting quality and sector-specific risk.

Recommended actions include a documented gap analysis against MOKAS findings, recalibration of alert logic, staff training on emerging typologies, and review of STR/SAR narratives for completeness and accuracy. Boards and MLROs should treat the report as part of ongoing financial crime risk governance. Effective use of the intelligence can improve detection, reduce false positives, and demonstrate a proactive risk-based approach.

Failure to act may increase exposure to supervisory scrutiny, remediation costs, and reputational damage. The report also offers an opportunity to benchmark controls against peer sectors and strengthen financial intelligence sharing.