Must UAE auditors report suspicious transactions found during an audit?
Yes. Where a UAE auditor suspects, or has reasonable grounds to suspect, that funds or a transaction relate to a crime, the proceeds of a crime, or terrorist financing, they must file a suspicious transaction report with the Financial Intelligence Unit immediately and without delay, regardless of the amount involved. Professional secrecy and contractual confidentiality cannot be invoked to avoid this duty.
Auditors are in a strong position to spot red flags because they examine books, records, and governance structures. If an audit surfaces unexplained wealth, circular transactions, or documents that do not reconcile, the firm should assess the pattern and, where suspicion is formed, report through goAML. The auditor must not tell the client that a report has been or will be made, as tipping off is a separate offence.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 18 — sets the obligation to file a suspicious transaction report immediately with the FIU.
· Federal Decree-Law No. 10 of 2025, Article 29 — criminalises tipping off a person that a report has been made.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.