Print Article

MAURITIUS: Financial sector must file plans to identify AML gaps


The Bank of Mauritius and the Mauritius Financial Services Commission have issued new anti-money laundering guidance, ordering all regulated entities to conduct a gap analysis against their requirements, and to submit plans to remedy any deficiencies in their risk-based approach, customer due-diligence, ongoing monitoring, reporting of suspicious transactions, record-keeping and employee training. Entities failing to comply with the guidelines may face regulatory action.

Mauritius’ Handbook and Guideline to strengthen their anti-money laundering and countering the financing of terrorism framework

Mauritius started the year on a high note in the area of anti-money laundering and countering the financing of terrorism (“AML/CFT”) by issuing two complementary documents: the Anti-Money Laundering and Countering the Financing of Terrorism Handbook: 2020 (the “Handbook”) and the Guideline on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation (the “Guideline”).

The Handbook

In January 2020, the Financial Services Commission (“FSC”) issued the Handbook, which is a consolidation of the FSC’s guidance on anti-money laundering and financing of terrorism and proliferation of weapons of mass destruction (“WMD”). It is also a supplement to the Code on the Prevention of Money Laundering and  Terrorist Financing, 2012 (as amended) (the “Code”).

The purpose of the Handbook is to provide financial institutions with guidance on applying national measures to combat money laundering and terrorist financing, and on complying with the requirements of the Financial Intelligence and Anti-Money Laundering Act, 2002 (“FIAMLA”), Financial Intelligence and Anti-Money Laundering Regulations, 2018 (“FIAML Regulations”) and the Code. Financial institutions should apply the Handbook when assessing the adequacy of their internal systems and controls and resolve any identified inadequacies, as failure to comply with these laws may result in regulatory action.

In assessing the level of compliance with these laws during onsite visits, the FSC will take the Handbook into account.

The Guideline

On 15 January 2020, the Bank of Mauritius (the “Bank”), as the designated AML/CFT supervisory authority of financial institutions, issued the Guideline under section 50 of the Bank of Mauritius Act, 2004.

In summary, the Guideline:

  • replaces the Guidance Notes on Anti-Money Laundering and Combating the Financing of Terrorism for Financial Institutions issued in terms of the Bank’s letter dated 20 January 2017;
  • applies to all financial institutions, members of their board of directors, management and employees;
  • outlines the relevant requirements of the FIAMLA, FIAML Regulations, Banking Act and the United Nations (Financial Prohibitions, Travel Ban and Arms Embargo) Sanctions Act;
  • sets out the broad parameters within which financial institutions should operate in order to address and prevent the risks of money laundering and financing of terrorism and proliferation;
  • provides financial institutions with guidance in order to assist them with understanding and effectively performing their statutory and regulatory obligations; and
  • provides practical guidance to assist financial institutions in designing and implementing AML/CFT policies, procedures and controls in the relevant areas of operation.

Failure to comply with provisions of the Guidelines may result in regulatory actions, including monetary penalties, the imposition of non-monetary sanctions, and in very serious instances, the revocation of the financial institution’s licence.

The Guideline requires all regulated entities to conduct a gap analysis against its requirements and formulate an implementation plan to address any identified gaps. The plan should then be submitted to the Bank upon request. Importantly, financial institutions must use the revised Guideline to conduct their 2020 AML/CFT external audits. The external audit should consider the status of a financial institution’s implementation plan in its assessment in the event that the financial institution would not have completed its implementation plan by the 2020 audit cycle.

The FSC’s Handbook and the Bank’s Guideline both cover the risk-based approach, customer due diligence, ongoing monitoring, reporting of suspicious transactions, record-keeping and employee training. As such, financial institutions should apply the minimum criteria set in the Handbook and Guideline in the event that there is knowledge, suspicion or reasonable grounds to suspect money laundering and financing of terrorism and proliferation.

The Handbook and Guidelines do not intend to cover guidance on all money laundering and financing of terrorism and proliferation of WMD risks that a financial institution may encounter or provide an exhaustive list of AML/CFT systems and controls and recommended practices. Financial institutions should, therefore, apply the guidance provided in a reasonable, proportionate, risk-based and outcome-focused manner.

Financial institutions should also take into consideration the factors outlined by the FSC and the Bank when identifying, assessing and mitigating the risks of these criminal activities and implement customised measures to combat money laundering and financing of terrorism and proliferation of weapons of mass destruction. Updated AML/CFT deterrence policies should be maintained and employees regularly trained on emerging typologies.

The costs of non-compliance with AML/CFT requirements can be devastating.

ENS Africa


The Team

Meet the team of industry experts behind Comsure

Find out more

Latest News

Keep up to date with the very latest news from Comsure

Find out more


View our latest imagery from our news and work

Find out more


Think we can help you and your business? Chat to us today

Get In Touch

News Disclaimer

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email