185 failed submissions

Cyprus's financial intelligence unit, MOKAS, says a suspicious transaction report fails submission if its narrative is not more than 400 and less than 4,000 characters, or if attachments or identity details are missing. 185 failed in 2025. Before quality, there is submission.

The document is MOKAS's Annual Sectorial Quantity and Quality Assessment of STRs/SARs submitted by obliged entities for the year 2025, issued in October 2026. It is an assessment by the FIU, not a law. ICPAC circulated it to all its members, firms and compliance officers on 5 October 2026, in Compliance Circular 29/2026.

The text is specific. The narrative of the report "should contain more than 400 and less than 4000 characters", so that it carries adequate background, the rationale for suspicion, relevant transactional details and supporting context; if that requirement is not fulfilled, the report fails submission. Reports submitted without attachments "will automatically fail the submission process". So will reports with missing or incomplete identification information for the subjects, and reports with missing or incomplete information relating to legal entities, which the FIU says it needs to identify and assess them, including legal name, registration number, jurisdiction of incorporation, business activities, registered address and beneficial ownership. In plainer words: a reason for suspicion that is too thin or too long, no supporting documents, or gaps in who the people and companies are, and the report does not go through.

Those are what the FIU calls the most common reasons, not the only ones. Its table counts 256 reasons for the 185 failed reports, because a report may fail for more than one: reason for suspicion 66 and attachments 66, 26% each; identification details 35; entity details 26; then date of birth, nationality, transaction details, report type, person's details and other.

The volumes behind it. The FIU received 24,092 reports in 2025, up from 3,870 in 2024. Of those, 21,857 came from obliged entities operating under the free provision of services, and only 246 of the 21,857 had a nexus with Cyprus; the rest concerned, and were disseminated to, other EU/EEA FIUs. Crypto-asset service providers alone submitted 20,570. From "traditional" obliged entities established in the Republic the total was 1,183, an increase of 16% on 2024. Lawyers submitted 33, company service providers 32, accountants and auditors 28.

Getting through is not the end. The most common deficiencies the FIU found in some of the reports it assessed include a weak reason for suspicion, with insufficient narrative, lack of supporting documentation or unclear grounds; report indicators used without clear explanation in the reason for suspicion; SARs submitted instead of STRs; and, in rare cases, late submission.

Since 1 May 2026 the FIU has adopted a new framework and feedback procedure for the quality assessment of submitted reports. Appendix 7.4 sets out the measures in 25 numbered rows, the last of which is "No Quality Issues Identified". Among them: timeliness (late submission between six months and one year, or over one year), the right report type, role clarity (subject, beneficiary, signatory), beneficial ownership, the linkage between accounts, persons and entities, and whether attachments are referenced in the narrative. The FIU says it will provide statistical feedback against these criteria at regular intervals, and quality assessment feedback every four months is to be provided to supervisory authorities and obliged entities.

The FIU also records no reporting at all from three categories: real estate agents, including as intermediaries in lettings where monthly rent exceeds €10,000; persons trading or acting as intermediaries in works of art, including in galleries and auction houses; and free ports storing, trading or acting as intermediaries in works of art, amounting to €10,000 or more.

So the new quality grading applies to reports that were submitted. Before any of it, a report has to get through: a narrative of more than 400 and less than 4,000 characters, the supporting documents attached, and the people and companies identified. In 2025, 185 did not.

Not legal advice. Verify against the primary source before acting.

Sources

• PRIMARY.
• CONTEXT.

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