Must attempted transactions be reported as STRs in the UAE?
Yes. UAE law makes clear that the duty to report suspicious activity is not limited to completed transactions. Where a reporting entity suspects, or has reasonable grounds to suspect, that a transaction, an attempted transaction, or funds constitute proceeds of crime or are related to or intended for use in a crime, it must file a report regardless of the value and regardless of whether the transaction was actually carried out.
This is important because criminals often abandon a transaction once they sense scrutiny, for example when asked for source-of-funds documents. An abandoned or refused transaction can be just as revealing as a completed one, and reporting it gives the Financial Intelligence Unit valuable intelligence. The same standards apply: notify the Unit without delay, include all available information, maintain confidentiality, and do not tip off the customer that a report has been or will be made.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 18(1) - expressly extends the reporting duty to attempted transactions and funds, regardless of value.
· Federal Decree-Law No. 10 of 2025, Article 18 - requires notification to the FIU without delay where a transaction or funds are suspected to relate to a crime.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.