Are you protected from liability when you file an STR in good faith in the UAE?
Filing a suspicious transaction report in good faith is a legal duty, not an admission of wrongdoing, and it is the mechanism the law expects entities to use. Federal Decree-Law No. 10 of 2025 Article 18 requires reporting to the FIU without delay and states that entities must provide the information without invoking confidentiality provisions, which removes the usual bank secrecy or professional confidentiality barrier to reporting.
The greater legal risk lies in not reporting, or in tipping off. Article 28 penalises failure to report, and Article 29 penalises disclosing that a report or investigation exists. Reporting entities and their staff should therefore file when reasonable grounds for suspicion arise and keep the matter confidential. Good-faith reporting made in line with Article 18 is how compliance officers discharge their obligation and protect the business from the far larger exposure of a reporting or tipping-off offence.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18: report without invoking confidentiality provisions.
· Federal Decree-Law No. 10 of 2025, Articles 28 and 29: penalties for failing to report and for tipping off.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.