Suspicious Transaction Reports in Tanzania: The 24-Hour Rule, the STR Form and Tipping-Off (2026)
Short answer: A reporting person in Tanzania that suspects funds or property are proceeds of crime, or linked to money laundering, terrorist financing, proliferation financing or a predicate offence, must report to the Financial Intelligence Unit (FIU) within 24 hours after forming the suspicion, and where possible before the transaction is carried out (section 18(1) of the Anti-Money Laundering Act, Cap. 423 R.E. 2023). Proposed and attempted transactions are covered. The FIU receives STRs through its goAML portal, and tipping off is a criminal offence.
This guide is for money laundering reporting officers (MLROs), compliance analysts and branch staff at banks, microfinance service providers, insurers, securities firms, bureaux de change, money transmitters and designated non-financial businesses and professions (DNFBPs) on Mainland Tanzania. It is a practical guide, not legal advice. Section numbers are those of the Revised Edition 2023. The Anti-Money Laundering Regulations, 2022 (GN No. 397) still use the old numbers, so their "section 17" is today's section 18.
The duty in section 18
Within 24 hours after forming the suspicion, and wherever possible before any transaction is carried out, the reporting person must:
- take reasonable measures to ascertain the purpose of the funds, property or transaction, the origin and ultimate destination of the funds or property, and the identity and address of any ultimate beneficiary; and
- prepare a report and submit it to the FIU "by any secure means as may be specified by FIU".
Since the Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022), the section also covers terrorist and proliferation financing, and "funds or property, transaction or proposed or attempted transaction". The FIU, or a law enforcement agency investigating the transaction, can ask for further information, which must be given (section 18(3)).
One deadline, three wordings
| Source | Wording |
|---|---|
| The Act, section 18(1) | "within twenty-four hours after forming that suspicion" |
| Anti-Money Laundering Regulations, 2022, regulation 21 | "not later than twenty-four working hours after a reporting person becomes aware or has knowledge of a suspicious transaction" |
| FIU compliance guide for DNFBPs, January 2023, paragraph 12.8 | "within 24 hours from the identification of the transaction as suspicious"; for attempted transactions, within 24 hours "or on the first business day, whichever is soonest" |
The texts differ on when the clock starts and on whether it counts working hours. Build your process to the Act: 24 hours from the moment the suspicion is formed. It is the statute, and it is stricter than the Regulations' working hours.
When to report
- No minimum amount. The FIU's DNFBP guide says: "There is no monetary threshold for making a report on a suspicious transaction." The guide applies the duty even where no transaction was conducted or the attempt failed.
- Unusual activity. Regulation 16 requires special attention to complex, unusual or large transactions, completed or not, and to "insignificant but periodic transactions" with no apparent economic or lawful purpose, with a prompt report where they are suspicious.
- Due diligence that cannot be completed. Section 16(1)(f) of the Act requires an STR "when customer due diligence cannot be completed". The Regulations, as amended by GN No. 10A in 2023, say "consider making" a report; follow the Act. Where due diligence would tip off the customer, the Regulations allow it to be stopped and an STR filed instead.
- DNFBPs, in defined situations. Since GN No. 853E of November 2023, regulation 16(3) limits the duty of lawyers, notaries, other independent legal professionals and accountants to client transactions in listed activities, such as real estate, client money and accounts, and managing legal persons. Dealers in precious metals or stones report on cash transactions with a customer at or above the shilling equivalent of USD 15,000, and trust and company service providers for listed services. The Written Laws (Miscellaneous Amendments) Bill, 2026 (Bill No. 1 of 2026) would move these limits into a new section 18A of the Act; on 1 October 2026 the Attorney General's list of 2026 Acts did not include it, so treat it as pending.
The DNFBP guide reminds staff that "behavior is suspicious, not people", and lists seven factors to weigh, such as an unusual size or pattern, no adequate explanation, offshore structures and unnecessary routing through third parties.
What the report must contain
Regulation 14 requires every STR to follow the form in the Schedule to the Regulations and to include a full description of the suspicious transaction, with the reasons for suspicion; the action the reporting person took; and copies of supporting documents. Regulation 17 lists the minimum transaction details, from the date, amount and currency to the method used, the other persons involved and the "suspected predicate offence". Regulations 18 to 20 add details for property, accounts and persons. For an account, they include transactions in the preceding six months that were considered for reporting, whether reported or not, and earlier report reference numbers.
| Part of the form | Content |
|---|---|
| A | The reporting person, including "Reason for suspicion", "Action taken" and "Report Indicators" |
| B | Transactions, with amounts in Tanzanian shillings |
| C | Natural persons involved, including their national identification number |
| D | Entities involved, including anyone holding 5% or more of the voting rights |
| E | Accounts |
| F | Supporting documents: identification, account opening and mandate documents, and transaction documents such as transfer instructions, statements and deposit or withdrawal slips |
Writing the narrative and linking reports
The FIU's DNFBP guide gives two practical rules. State in the narrative field how many suspicious transactions are involved, and attach the transaction details separately. In a later STR on the same suspect, say that it relates to the earlier one and include the earlier STR's reference number.
A narrative that meets regulation 14 explains the reasons for suspicion and what the institution did about them. The guide's Annex B lists indicators, such as a customer who "attempts to divide the amounts of any operations below the applicable designated threshold of reporting"; the thresholds are in our CTR and EFT guide.
Internal reporting and records
Regulation 15 requires written internal reporting procedures: an MLRO who is "a senior officer at management level", a clear reporting chain, and a register of every report made to the MLRO, with the suspect's details, the date, the reporter, the property, the amount and currency, and the grounds for suspicion. Under section 19(1), the MLRO must have reasonable access to information and reports suspicious activity to the FIU.
Keep STRs and the results of any analysis for at least ten years (section 17), and longer where the competent authority requires it. For what to test in software that runs this workflow, see our buyer's guide to AML compliance software in Tanzania.
After you file
- Feedback. Regulation 26 requires the FIU to acknowledge receipt of STRs, and to tell reporting persons whether criminal proceedings have been instituted and about court decisions.
- Suspension. On reasonable grounds, the FIU's Commissioner may suspend a reported transaction or activity for up to five working days to allow investigation (section 6(3)).
- Requests. When the FIU asks for information under regulation 25, the reporting person must provide it within three working days.
Tipping off and protection
Section 22 prohibits disclosing to anyone involved in the transaction, or to an unauthorised third party, that an STR "may be prepared, or is being prepared or has been sent to the FIU".
In return, no criminal, civil or administrative proceedings for breach of banking or professional secrecy or contract may be brought against a reporting person, its employees or its partners who, in good faith, submitted a report or supplied information under the Act (section 24). Section 23 gives Part IV of the Act, which contains these duties, effect "notwithstanding any obligation as to secrecy".
Penalties
| Failure | Consequence |
|---|---|
| Not reporting (section 18(4)) | Individual: fine of up to TZS 5 million or up to five years' imprisonment. Body corporate: fine of up to TZS 10 million or three times the market value of the property, whichever is greater |
| Tipping off (section 22(2)) | Individual: fine of TZS 100 million to 500 million, or five to ten years' imprisonment. Body corporate: fine of TZS 500 million to 1 billion, or three times the market value of the property, whichever is greater |
| Failures under section 15, 17, 18 or 19 (section 21) | Administrative sanctions by the FIU or regulator: warning or caution, reprimand, remedial directives, restriction or suspension of business activities, suspension of a business licence, or suspension or removal of the staff member responsible |
Since the Written Laws (Miscellaneous Amendments) Act, 2025, a regulator without the mandate to impose one of these sanctions must recommend it to its "relevant authority".
Section 21 lists no fines. The FIU's 2024 enforcement manual for supervisory authorities sets minimum penalties, best treated as FIU enforcement guidance rather than fines set by the Act: TZS 300,000 on the chief compliance officer and TZS 5,000,000 on the institution for failing to submit an STR; TZS 5,000,000 for having no internal system to detect and report unusual and suspicious transactions; and TZS 5,000,000 on an officer who breaches the confidentiality procedures.
Filing on goAML
STRs are filed on the FIU's goAML portal, goaml.fiu.go.tz, once your organisation and its users are registered: see our goAML registration guide. The DNFBP guide says that if the electronic system is not available, an STR can be sent by letter to the Commissioner of the FIU at 1 Madaraka Street, Dar es Salaam. See also our Tanzania FIU goAML reporting guide and our guide to Tanzania's Anti-Money Laundering Act and 2022 Regulations.
What the published figures show
The STR figures we can cite are old, and the two sources count differently:
| Source | Period | STRs received |
|---|---|---|
| FIU Annual Report 2014/15 | Financial years 2010/11 to 2014/15 | 15, 20, 57, 86 and 142: 320 in total, "mainly from banking sector" |
| ESAAMLG mutual evaluation, June 2021 | Calendar years 2014 to 2018 | 81, 197, 248, 477 and 1,095: 2,098 in total, 98% from banks |
Because one counts financial years and the other calendar years, the 2013/14 and 2014 figures are not comparable. ESAAMLG also found that only around 7% of STRs led to disseminations to law enforcement agencies, and that the FIU acknowledged STRs without case-specific feedback. It rated Tanzania Largely Compliant with FATF Recommendation 20, on suspicious transaction reporting.
STR checklist
- Write the section 18 triggers into your procedures, and train staff at least every twelve months (regulation 24(3)).
- Give staff a clear reporting chain to the MLRO, and log every internal report in the regulation 15 register.
- Record the time each suspicion is formed: the 24-hour clock starts then.
- Complete every applicable part of the Schedule form, including the reasons for suspicion and the suspected predicate offence.
- Cite earlier STR reference numbers when you report the same suspect again.
- Answer FIU requests for information within three working days.
- Keep each report confidential, and keep STRs and analysis for at least ten years.
Frequently asked questions
What is the STR deadline in Tanzania?
Within 24 hours after forming the suspicion, and where possible before the transaction (section 18(1)). The 2022 Regulations say 24 working hours; build your process to the Act.
Is there a minimum amount for an STR?
Not in general: the FIU's DNFBP guide says there is no monetary threshold. Since November 2023, though, dealers in precious metals or stones report on cash transactions at or above the shilling equivalent of USD 15,000.
Do attempted transactions have to be reported?
Yes. Since Act No. 2 of 2022, section 18 covers proposed and attempted transactions.
Can we tell the customer that we filed an STR?
No. Section 22 makes it an offence to disclose that an STR may be prepared, is being prepared or has been sent.
What happens if we do not report?
It is an offence under section 18(4), and the FIU or regulator can impose administrative sanctions under section 21. The FIU's 2024 enforcement manual adds minimum penalties on the chief compliance officer and the institution.
Suspicious transaction reporting with Creodata
Creodata's goAML Reporting Platform compiles parties, accounts and narrative in one STR workspace, generates schema-valid goAML XML from core-banking data, 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 Tanzania, and AML compliance software in Tanzania for the monitoring and case management behind each report.
See it on your own cases — request a demo.
More guides for Tanzania
- Tanzania FIU goAML Reporting: A Practical Guide for Banks
- FIU goAML Registration in Tanzania: Who Registers, the Portal's Steps and What to Prepare (2026)
- Cash Transaction Reports in Tanzania: USD 10,000 CTRs, USD 1,000 EFT Reports and the Five-Working-Day Deadline (2026)
- Tanzania's Anti-Money Laundering Act, Cap. 423, and the Anti-Money Laundering Regulations, 2022 Explained
- AML Compliance Software in Tanzania: A Buyer's Guide for Banks, SACCOS and Fintechs (2026)