Is there a minimum transaction value for filing a Suspicious Transaction Report as a UAE DNFBP?
No. There is no minimum monetary threshold for a Suspicious Transaction Report (STR) in the UAE. A Designated Non-Financial Business or Profession (DNFBP) must report to the Financial Intelligence Unit whenever it suspects, or has reasonable grounds to suspect, that funds or a transaction, in whole or in part, represent proceeds of crime or are related to or intended for terrorist or proliferation financing, regardless of the amount involved.
This is a key distinction from value-based reports such as the Dealers in Precious Metals and Stones Report, which is tied to the AED 55,000 threshold. A suspicion can attach to a small transaction, an attempted transaction, or even a customer who declines to proceed once due diligence questions are asked. The report must be made without delay and directly to the FIU through the goAML portal, with all available data, and the DNFBP may not invoke confidentiality to withhold it. Tipping off the customer that a report has been or may be made is prohibited.
The practical implication is that staff should be trained to escalate on the basis of behaviour and red flags, never waiting for a value threshold to be reached.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18(1) — obligation to report suspicious transactions regardless of value, without delay.
· Federal Decree-Law No. 10 of 2025, Article 18(2) — limited professional-secrecy exception for certain legal professionals.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.