Suspicious Transaction Reports in Ghana: The FIC's 24-Hour Rule, Triggers and Tipping-Off (2026)

Short answer: An accountable institution in Ghana that knows or reasonably suspects that someone has received proceeds of unlawful activity, or that a transaction has no apparent lawful purpose, was structured to avoid reporting or may involve tax evasion, must file a suspicious transaction report (STR) with the Financial Intelligence Centre (FIC) within 24 hours (section 38 of the Anti-Money Laundering Act, 2020, Act 1044). There is no minimum amount, attempted transactions count, and tipping off the customer is an offence.

This guide is for Anti-Money Laundering Reporting Officers (AMLROs), compliance analysts and branch staff at Ghanaian banks, specialised deposit-taking institutions, insurers, securities firms, payment and remittance businesses, casinos and designated non-financial businesses and professions (DNFBPs). It is a practical guide, not legal advice: Act 1044, the Anti-Money Laundering Regulations, 2011 (L.I. 1987) and the FIC's guidance are the authoritative texts.

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When the duty arises

Section 38 of Act 1044 sets two triggers. An accountable institution files an STR if it knows or reasonably suspects that:

• someone has received, or is about to receive, the proceeds of unlawful activity: an individual, a business entity, an accountable institution or a trust; or
• a transaction to which a business entity is a party:
  • facilitated, or is likely to facilitate, the transfer of proceeds of unlawful activity;
  • has no apparent business or lawful purpose;
  • is conducted to avoid, or to give rise to, a reporting duty under the Act;
  • may be relevant to an investigation into tax evasion, or an attempt to evade a tax, duty or levy; or
  • has been used, or is about to be used, for money laundering.

An institution that knows or reasonably suspects that property is the proceeds of unlawful activity also files an STR, within 24 hours after the knowledge or suspicion was formed (section 38(2)).

Three points widen the net:

• No minimum amount. The FIC's report types page says "there is no threshold for reporting suspicious activity or transaction", and L.I. 1987 requires a report regardless of the amount involved or whether tax matters are thought to be involved (regulation 33).
• Attempted transactions count (section 38(3)). A transaction the customer abandons can still be reportable.
• The FIC can ask. It may request an institution to make a report (regulation 33(2)).

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STR or SAR?

The FIC receives both. Its 2022 annual report describes suspicious transaction reports as reports "on financial transactions deemed suspicious", and suspicious activity reports as reports that are "not necessarily based on financial transactions but rather on the unusual/suspicious behavioral patterns of a person seeking to conduct a financial transaction". The Bank of Ghana and FIC sanctions schedule treats a failure to file either one the same way, and the FIC's 2022 annual report counted both as STRs. Choose the report type that describes what you saw, and treat both with the same 24-hour discipline.

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The 24-hour clock

The Act gives 24 hours "after the knowledge or the ground for suspicion of the transaction". It does not give 24 hours after the transaction. L.I. 1987 sets out the internal chain that has to fit inside that time (regulation 34):

The Bank of Ghana and FIC guideline for banks and non-bank financial institutions adds that staff who detect a red flag report "promptly" to the AML/CFT reporting officer and that "every action taken shall be recorded". That record matters twice: it shows when the suspicion was formed, and it shows why an alert was closed without a report.

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Unusual transactions: record within 24 hours

Separately from the STR duty, an accountable institution must pay special attention to complex or unusually large transactions, and to unusual patterns, with no apparent economic or lawful purpose. It must also watch business with countries that do not sufficiently apply the FATF Recommendations. It examines the background and purpose, records its findings in writing within 24 hours and forwards them to the Centre (section 30 of the Act; regulation 32 of L.I. 1987).

Non-financial accountable institutions have their own triggers in regulation 32(3):

• Casinos: a financial transaction at or above the amount the Bank of Ghana prescribes.
• Dealers in precious metals or stones: a deal at or above the amount the Bank of Ghana prescribes.
• Real estate agents: buying or selling property for a client in suspicious or unusual circumstances.
• Lawyers, notaries, accountants and other independent legal professionals: specified client work carried out in a suspicious or unusual manner. That work includes real estate, client money, accounts, company formation and management, trusts and nominee arrangements.

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Hold or proceed?

An accountable institution must not proceed with a transaction it knows or reasonably suspects to be related to money laundering, terrorist financing, proliferation financing, tax evasion or any other unlawful activity "until the Centre directs otherwise" (section 45(1)). Where stopping it is not possible, or would be likely to frustrate efforts to investigate it, the institution executes the transaction and immediately makes a report under section 38 (section 45(2)).

The FIC can then act:

• Suspension: the Centre may order a transaction suspended for up to seven working days (section 45(3)).
• Freezing order: its Chief Executive Officer may apply to court within seven days for a freezing order (section 45(4)).
• Notice: the affected person is informed within 48 hours and may seek redress from the court (section 45(5)).

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Tipping-off and confidentiality

An accountable institution must not disclose to the customer, or to a third party, that a report will be, is being or has been submitted to the Centre, or that an investigation is being or has been carried out (section 38(4)). The exceptions are narrow:

• a disclosure needed to carry out a function in enforcing the Act or another law;
• for a lawyer, notary or accountant, one made to dissuade a client from unlawful activity.

The institution also may not disclose information that identifies who prepared the report, who provided information for it or who handled the transaction. The report, its contents and those identities may be disclosed in judicial proceedings only where necessary in the interest of justice, and then only to a judge (section 38(6)–(7)).

In return, the Act protects reporters. No criminal, civil or administrative action lies against an accountable institution, its directors, officers or employees for breaching a disclosure restriction when they comply in good faith with the duty to file an STR or provide information to the Centre (section 44(1)).

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Penalties

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Filing on goAML

STRs reach the FIC through its goAML portal, reporting.fic.gov.gh: its 2023 annual report says section 38 reports were "received through the goAML platform". The Centre received 2,152 suspicious transaction and activity reports that year and disseminated 192 of them as intelligence reports to law enforcement agencies.

A report the FIC can use explains who, what, when and why: the parties and accounts involved, the transactions, and the facts that led to the suspicion. See how to write an STR narrative for goAML. For access to the portal, see our FIC goAML registration guide, and for the other report types, our Ghana FIC goAML reporting guide.

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STR checklist

1. Write the section 38 triggers, including attempted transactions and tax evasion, into your internal rules and staff training.
2. Give staff a quick route to the AMLRO, and record when each internal report was made.
3. Record the AMLRO's decision and reasons for every internal report, whether or not it becomes an STR.
4. File within 24 hours of the suspicion, not of the transaction.
5. Hold the transaction until the FIC directs otherwise, or execute it and report immediately where stopping it is not possible or would frustrate an investigation.
6. Keep reports and reporters' identities confidential, and train customer-facing staff on tipping-off.
7. Keep copies of STRs for at least five years from the date of the report (section 32).

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Frequently asked questions

What is the STR deadline in Ghana?

Within 24 hours after the knowledge or the ground for suspicion, under section 38 of Act 1044. The clock starts when the suspicion is formed, not when the transaction took place.

Is there a minimum amount for an STR in Ghana?

No. The FIC says there is no threshold for reporting suspicious activity or transactions, and L.I. 1987 requires a report regardless of the amount involved.

Do attempted transactions have to be reported?

Yes. Section 38(3) of Act 1044 applies the STR duty to attempted transactions.

Can we tell the customer that we filed an STR?

No. Disclosing to the customer or a third party that a report has been or will be filed, or that an investigation is under way, is an offence. The exceptions are narrow: enforcement functions, and a lawyer, notary or accountant dissuading a client from unlawful activity.

What happens if we do not file an STR?

Failing to file within the time limit is an offence under section 48 of Act 1044, punishable by fines in penalty units or imprisonment. The FIC or a supervisory body can also impose administrative penalties, including on the AMLRO personally.

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Suspicious transaction reporting with Creodata

Creodata's goAML Reporting Platform compiles parties, accounts and narrative in one STR workspace, generates schema-valid goAML XML, validates every report against the schema and business rules before submission, and keeps an immutable record of every report, amendment and filing. See goAML reporting software for Ghana, and AML compliance software in Ghana for the transaction monitoring and case management that raise and document the suspicion.

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