Do lawyers have to report suspicious transactions in the UAE?
Yes. When a lawyer acting as a DNFBP suspects, or has reasonable grounds to suspect, that funds or a transaction represent proceeds of crime or are linked to money laundering or terrorist financing, the firm must file a suspicious transaction report with the UAE Financial Intelligence Unit without delay through the goAML portal. Confidentiality clauses in a retainer cannot be used to avoid this duty.
The report must contain all available data on the transaction and the parties involved, and the firm must supply any further information the FIU requests. Tipping off the client that a report has been or may be filed is prohibited. Late or omitted filing is one of the most common findings raised by supervisors during inspections, so firms should have a clear internal escalation route to the compliance officer.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18(1) - requires DNFBPs to notify the FIU without delay of suspicious transactions, without invoking confidentiality.
· UAE Financial Intelligence Unit - goAML reporting - the official channel for filing suspicious transaction reports.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.