Suspicious Transaction Reports to the ANRF: When and How

What the law says#

The ANRF, Morocco's financial intelligence unit, replaced the UTRF following Law No. 12-18. The law also requires reporting entities to notify it of the identity of the managers or staff authorised to deal with it. To find out whether your files fall within scope, see the AML/CFT obligations of non-financial professions.

What should raise a suspicion?#

A suspicion arises from a mismatch between what you know about the client and what they are asking you to do. The signals below, drawn from international typologies, are not proof: they call for analysis.

Real estate

• payment of a large part of the price in cash, or funds coming from third parties with no apparent link to the buyer;
• a price well above or below market value, with no explanation;
• rapid successive resales of the same property with an unexplained capital gain;
• a buyer who cares about neither the property nor the price, only about speed.

Company formation and management

• layered structures with no economic justification;
• a beneficial owner who cannot be established, or shareholders who appear to be nominees;
• capital contributions or share transfers at inconsistent prices;
• a request for a registered office with no visible real activity.

Cash and flows

• splitting payments to stay below a given amount;
• refusal to disclose the source of funds;
• frequent changes of accounts, countries or intermediaries.

Behaviour

• a client who refuses to provide documents or provides inconsistent ones;
• insistence on avoiding anything in writing;
• unusual interest in the firm's reporting obligations.

The law leads directly to considering a report where due diligence cannot be completed (Article 4). In addition, a complex or unusual transaction that remains unexplained after the scrutiny required by Article 8 should, in practice, lead to considering a report. A well-maintained risk-based approach helps spot these mismatches early.

The internal procedure: good practice#

The law sets the obligation and the written form. Internal organisation is a matter for each firm and for any detailed rules issued by the supervisory authorities. Here is a good-practice procedure:

1. Internal alert. Any member of staff who spots a signal passes it in writing to the AML/CFT officer, without mentioning it to the client or to colleagues who are not involved.
2. Analysis. The officer assembles the file: identification, beneficial owner, transaction, correspondence. If needed, they ask the client for explanations as part of normal due diligence, without referring to any suspicion.
3. Decision. The officer, or a designated partner, decides whether or not to report. The decision and its reasons are put in writing, including when no report is made.
4. Report. The report is sent to the ANRF without delay, in writing, in the manner it prescribes. It describes the facts, the persons, the amounts and the grounds for suspicion.
5. Next steps on the file. The firm decides whether to continue, suspend or end the relationship, taking care not to alert the client.
6. Record keeping. The documents are kept for ten years (Article 7), in a restricted-access area separate from the live client file.

Confidentiality and the tipping-off prohibition#

Article 29 punishes knowingly disclosing the report or its follow-up. As a precaution, good practice is to limit information internally: no mention in the file shared with the team, no email to an uninvolved colleague, no message in a chat group. Data protection for these files follows the rules of Law 09-08 as applied to KYC.

Professional secrecy for lawyers and notaries#

Article 13 of Law 43-05 means professional secrecy cannot be invoked against the ANRF or the supervisory authorities. The consolidated law provides neither a filter through the head of the Bar nor an explicit exemption for legal advice or litigation: lawyers report directly to the ANRF, but only for the transactions in Article 5. The MENAFATF follow-up report published in 2022 noted that the Ministry of Justice guidance of January 2022 did not clarify this point.

Law No. 66.23 on the legal profession, published in the Official Bulletin on 21 August 2026, strongly reaffirms professional secrecy and the confidentiality of lawyer-client communications. The press does not attribute any provision on suspicious transaction reporting to it. Until the relationship between the two texts is clarified, it is prudent to seek the advice of your own adviser or your Bar on sensitive files.

What not to do#

• Warn the client, even implicitly ("we have had to report your file").
• Wait for proof: suspicion is enough.
• Decide not to report because the transaction has already been carried out (Article 11).
• Conduct your own investigation with third parties.
• Leave the suspicion only in a staff member's memory, with no written record.
• Keep the report in the client file accessible to the whole team.

Checklist#

• An AML/CFT officer has been appointed and their identity notified to the ANRF.
• The list of red flags is tailored to your activities.
• The internal alert procedure is written down and known to staff.
• Every decision, whether to report or not, is reasoned in writing.
• Reports are kept separately, with restricted access.
• The team is trained on the tipping-off prohibition.