CySEC Circular C805: MOKAS assessment of 2025 suspicious transaction reports

With Circular C805, dated 9 October 2026, CySEC informs its regulated entities that MOKAS, the Unit for Combating Money Laundering and Cyprus's financial intelligence unit, has published its Annual Sectorial Quantity & Quality Assessment of the STRs and SARs that obliged entities submitted in 2025. The report is attached to the circular. CySEC describes it as a valuable tool that helps obliged entities focus on high-risk areas sector by sector.

The circular lists the five risk indicators most often behind a report in 2025: transactions related to virtual assets, use of money mules, transactions between unrelated counterparties, internet fraud and cyber crime, and money laundering. It notes that, despite a commendable improvement in overall quality, MOKAS found deficiencies in some reports when it checked them against its Reporting Guidelines. CySEC encourages firms to study the report and to keep improving the reports they submit. There is no new obligation and no deadline.

MOKAS received 24,092 reports in 2025, against 3,870 in 2024. Of these, 21,857 came from obliged entities licensed in Cyprus that operate in other EU countries under the freedom to provide services; only 246 of them had a link with Cyprus, and the rest were passed to other EU/EEA financial intelligence units. CASPs alone filed 20,570 reports, of which 172 had a Cyprus link. Investment firms filed 980, up from 347 in 2024, and 26 of these had a link with Cyprus. Banks, payment institutions, gambling providers, lawyers, company service providers, accountants and other obliged entities established in Cyprus, which MOKAS calls traditional obliged entities, filed 1,183, 16% more than in 2024.

For investment firms, most reports rested on suspected fraud, including cyber fraud, activity with no economic rationale, unusual client behaviour, fake documents and insufficient documentation. CASPs most often cited suspected money mules. MOKAS made 572 disseminations of financial intelligence in 2025, against 205 in 2024, most of them to the Police. MOKAS also notes that it received no reports at all from real estate agents or from persons trading in works of art.

In 2025, 185 reports failed submission. A report fails automatically if the reason for suspicion is not more than 400 and less than 4,000 characters long, if the supporting documents are not attached, or if identification details of a person or an entity are missing or incomplete. The reason for suspicion and missing attachments were the two most common causes, each in 26% of the failure reasons recorded (a report can fail for more than one reason).

Among the reports that went through, MOKAS's most common quality deficiencies were: a weak reason for suspicion, with an insufficient narrative, no supporting documentation or unclear grounds; risk indicators selected without a clear explanation in the reason for suspicion; SARs submitted instead of STRs; and, in rare cases, late submission. MOKAS says it raised these findings with the entities concerned case by case, with guidance on the corrective measures required.

Read the report, in particular the pages for your sector and the quality measures in its appendix, which cover timeliness, report type, persons, entities, accounts, transactions, indicators, the reason for suspicion and attachments. Check a sample of your own recent reports against them: the reason for suspicion should explain clearly why the activity is suspicious, match the indicators selected and the transactions reported, and refer to the attachments.

Under its new framework, applied since 1 May 2026, MOKAS assesses submitted reports against these measures and gives statistical feedback at regular intervals, including quality feedback every four months. Entities that filed more than 4 reports in 2025 received individual yearly feedback. Act on any feedback your firm receives, and build the findings into reporting procedures and staff training. For the reporting steps themselves, see our study note on reporting to MOKAS.