Do lawyers have to report suspicious transactions in the UAE?
Yes, as a general rule. When a law firm acting as a DNFBP suspects, or has reasonable grounds to suspect, that a transaction or funds represent proceeds of crime or relate to money laundering or terrorist financing, it must file a Suspicious Transaction Report with the Financial Intelligence Unit through the goAML portal without delay, and cannot invoke confidentiality to avoid doing so.
There is a narrow exemption discussed separately for information obtained under professional secrecy while assessing a client’s legal position or representing them in proceedings. Outside that carve-out, the reporting duty is firm. Tipping off is prohibited, so the lawyer must not tell the client that a report has been or will be filed. Failing to report a genuine suspicion can expose the firm and individuals to administrative and criminal liability.
Legal Reference (UAE):
· Federal Decree-Law 10/2025, Article 18(1) — obligation to report suspicious transactions to the Unit without delay.
· Cabinet Resolution 134/2025, Article 19 — prohibition on tipping off the customer.
For more details, consult the full text of Federal Decree-Law 10/2025 or seek guidance from your AML compliance officer.