Do lawyers have to report suspicious transactions in the UAE?
Yes, in most cases. Where a lawyer acting as a DNFBP suspects, or has reasonable grounds to suspect, that funds or a transaction represent proceeds of crime or relate to money laundering or terrorist financing, the lawyer must notify the Financial Intelligence Unit without delay through the goAML system, regardless of the amount involved. Confidentiality provisions cannot be used to withhold the report.
The report must contain all available data and information on the transaction and the parties, and the firm must supply any further details the Unit requests. Filing a suspicious transaction report is a legal duty, and lawyers must not tip off the client that a report has been made. There is one narrow exception based on professional secrecy, which applies only to information obtained while advising on or defending a client in legal proceedings.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18(1) — requires reporting of suspicious transactions to the Unit without invoking confidentiality.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 18 — sets the rules and cases for reporting suspicious transactions.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.