The rising tide of suspicious activity reports: Challenges for MROS

MROS has experienced a sharp rise in SAR volumes, with a 40% increase in 2025 compared to 2024 (from 15,141 cases to 21,087). According to its head, Anton Brönnimann¹⁾, MROS expect to receive between 30,000 and 40,000 SARs/STRs (Suspicious Transaction Reports)²⁾ in 2026. This rise is driven not only by technological advancements and behaviour-based transaction monitoring but also by growing regulatory pressure, increased awareness across the financial sector, and the fear of personal sanctions (including criminal prosecution at Compliance Officer level).

At the same time, a trend toward “defence reporting” - where institutions file reports to mitigate the risk of underreporting - has further intensified MROS’s workload. MROS has observed an overall decline in SAR data quality, with many containing incorrect, incomplete, or low evidentiary value information. Investigations are often submitted prematurely or based on isolated indicators, without a full assessment of underlying contexts or linkages.

The combination of rising volumes, increasing case complexity, and declining data quality places significant pressure on MROS’s team. Although MROS applies a risk-based approach - prioritising cases linked to terrorism financing, organised crime, and major financial offences - resource constraints mean that some reports risk being overlooked. According to Brönnimann, the team would need to double in size to manage the caseload effectively.

Recognising these capacity challenges, the Swiss Federal Council tasked the Federal Department of Justice and Police (FDJP) in September 2025 with examining alternative funding models for MROS, including a fee-based system. Specific proposals, supported by the Federal Department of Finance (FDF), are expected by the end of 2026. Establishing a sustainable funding model would mark an important step toward strengthening the long-term operational capability of Switzerland’s financial intelligence framework.

In its 2024 Annual Report published in May 2025, MROS highlighted the urgent need to streamline reporting processes and enhance efficiency through targeted investment in IT infrastructure. Modern analytical tools capable of processing large, complex datasets are becoming indispensable, given the volume of information involved. Just like financial institutions, FIUs need to be able to rely on advanced, compliant software to ensure timely and effective analysis. Further to address these challenges, MROS announced the launch of the “FIU 2.0” study in early 2026, which will propose concrete measures and include an international benchmarking of its capabilities.

Further guidance for financial institutions to improve reporting quality came in August 2025, when MROS published its first Negative Typology Report. Unlike traditional typology reports, which illustrate when a SAR is required, this new report provided examples where a SAR may not be required. Its objective is to ensure that reports are grounded in well-founded, objectively verifiable facts rather than filed defensively.

One thing is clear: there will be no way around using AI tools in the future when it comes to fighting financial crime. According to the circular 20241122-3-EN issued by the Hong Kong Monetary Authority (HKMA), Authorized Institutions are expected to adopt AI‑enabled monitoring systems, which are considered far more effective than traditional ones. For FIs operating in Hong Kong, AI adoption is now a regulatory expectation. In short, “Adopt AI for suspicious activity monitoring - or justify why not.”

This trend is not limited to Hong Kong. Globally, regulatory bodies are increasingly expecting the use of AI in combating financial crime. When deployed efficiently, AI can greatly support not only FIs but also Financial Intelligence Units (FIUs), such as MROS, by automating routine tasks, transaction monitoring, and improving the speed and quality of analysis. However, these benefits depend on thoughtful implementation paired with strong human oversight to ensure reporting quality, data accuracy, and high investigative standards.

Ultimately, striking the right balance between AI-driven efficiency and human judgment will be key. When applied wisely, AI has the potential to reduce unnecessary reporting, ease the workload of MROS, and help both FIs and the authority prioritize high-risk, high-impact cases - effectively strengthening the fight against financial crime.