Can an accountant face criminal liability for failing to report suspicious transactions in the UAE?

UAE
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Can an accountant face criminal liability for failing to report suspicious transactions in the UAE?

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Yes. In the UAE, failing to report a suspicious transaction when required to do so is a serious offence. Under Federal Decree-Law No. 10 of 2025, any person who intentionally or through gross negligence fails to file a Suspicious Transaction Report (STR) when they had reasonable grounds to suspect money laundering or terrorism financing can face both administrative and criminal consequences.

Administratively, the Supervisory Authority may impose fines ranging from AED 10,000 to AED 5,000,000 per violation under Article 17 of Federal Decree-Law No. 10 of 2025. In addition, regulators may suspend the accountant’s licence, restrict their professional activities, or require the appointment of a temporary supervisor.

At the criminal level, individuals, including senior management and the MLRO, can be held personally liable where the failure to report was intentional. The UAE’s enforcement framework has been significantly strengthened under the 2025 legislation, with greater focus on individual accountability at the board and senior management level. An accountant who assists a client in structuring transactions to avoid detection faces the additional risk of being prosecuted for complicity in money laundering.

Legal Reference (UAE):

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

AML Compliance Requirements for Auditors and Accountants in the UAE