What are the consequences for an accountant in the UAE who fails to report a suspicious transaction?
What are the consequences for an accountant in the UAE who fails to report a suspicious transaction?
The failure to file a Suspicious Transaction Report (STR) is one of the most serious compliance breaches under UAE AML law and carries significant consequences for both the individual accountant and the firm.
Under Federal Decree-Law No. 10 of 2025, administrative penalties for an STR filing failure can reach AED 5,000,000 per violation. Criminal liability is also possible under Articles 22 to 24 of the law, which address wilful participation in or facilitation of money laundering. In practice, enforcement has become increasingly active following the UAE’s 2024 FATF delisting, and the Ministry of Economy has signalled an ongoing focus on DNFBP sector compliance.
Beyond financial penalties, an accountant or audit firm found to have knowingly or negligently failed to report suspicion faces revocation of their professional licence, reputational damage, and potential civil liability. Senior management and the appointed MLCO may also be held personally accountable if adequate oversight processes were not in place. The law provides a safe harbour for accountants who file STRs in good faith, meaning that reporting a suspicion, even if it later proves unfounded, does not expose the accountant to liability.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 18 (STR obligation), Articles 22 to 24 (criminal liability), Article 17(1)(b) (administrative penalties up to AED 5,000,000)
- NAMLCFTC – publishes enforcement guidance and sector-specific compliance expectations