Linked transactions are two or more dealings that individually sit below AED 55,000 but which, taken together, appear connected and cross that threshold. The Executive Regulations treat such linked dealings the same as a single transaction of the combined value, so the DPMS reporting and due diligence obligations are triggered once the aggregate reaches AED 55,000.
The concept exists to stop structuring, where a customer deliberately splits a large purchase into several smaller payments, often across different days, to stay under the reporting line. Indicators of linkage include the same customer, the same or related goods, payments close in time, and amounts that sit suspiciously just below the threshold. Dealers should therefore monitor cumulative customer activity rather than assessing each receipt on its own, and treat repeated just-under-threshold buying as a red flag warranting closer scrutiny and possibly a suspicious transaction report.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3(3) — applies the AED 55,000 trigger to a single transaction or several linked transactions.
- Federal Decree-Law No. 10 of 2025, Article 18 — requires reporting of suspicious transactions regardless of value.
For more details, consult the full text of Cabinet Resolution 134 of 2025 or seek guidance from your AML compliance officer.