Do attempted transactions need to be reported as STRs in the UAE?
Yes. Federal Decree-Law No. 10 of 2025 Article 18 expressly covers transactions and funds that are suspected of representing proceeds or being linked to a crime, and the duty is not limited to completed transactions. If a customer attempts a transaction that raises reasonable grounds for suspicion and then abandons it, or you decline it, the suspicion must still be reported to the FIU without delay.
A common mistake is to assume that because no money moved there is nothing to report. Attempted transactions are often the clearest signal of intent, for example a customer who withdraws a request the moment you ask for source-of-funds evidence. Report the attempt through goAML with the available details and the grounds for suspicion. The same confidentiality and no-tipping-off rules apply, so the customer should not be told a report was made.
Legal Reference (UAE):
ยท Federal Decree-Law No. 10 of 2025, Article 18: covers transactions and attempted transactions alike.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.