Yes. The duty to file a suspicious transaction report is not tied to any monetary threshold. If a regulated entity suspects, or has reasonable grounds to suspect, that a transaction or funds represent proceeds of crime or are linked to money laundering, terrorist financing or proliferation financing, it must report regardless of the amount involved.
Under Federal Decree-Law No. 10 of 2025, the entity must notify the Financial Intelligence Unit without delay and directly, through the electronic system designated by the Unit, providing a detailed report with all available information, and must supply any further information requested without invoking confidentiality. The AED 55,000 figure people often cite is a customer due diligence trigger for occasional customers, not a reporting floor. A small transaction can still be highly suspicious, for example structured payments designed to stay under a threshold, and it must be reported through goAML.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 18(1) — duty to report suspicious transactions to the FIU regardless of value.
- Federal Decree-Law No. 10 of 2025, Article 28 — penalty for failing to report.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.