Can a business proceed with a transaction after filing an STR in the UAE?
Filing a suspicious transaction report does not automatically require a business to halt the transaction, but it does not give a clean bill of health either. Whether to proceed depends on the circumstances and on any instructions from the Financial Intelligence Unit. The entity must never tip off the customer that a report has been filed, so any decision to pause or continue must be handled discreetly and consistently with the customer’s normal experience where possible.
The FIU has powers to intervene. It can direct the suspension of a suspicious transaction for a defined period while it analyses the report, and the Chief of the Unit can order the freezing of funds suspected of being linked to a crime. If the entity receives such a direction, it must comply. In targeted financial sanctions cases the position is different and stricter: a confirmed match requires an immediate freeze rather than a judgment call, and the transaction cannot proceed.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 51 - empowers the FIU to order suspension of suspicious transactions and freezing of suspected funds.
· Federal Decree-Law No. 10 of 2025, Article 18 - requires the report to be filed without delay while confidentiality is maintained.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.