What happens if a UAE law firm tips off a client about a suspicious transaction report?

UAE
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Tipping off is prohibited. A law firm and its staff must not disclose to a client or any other person that a Suspicious Transaction Report has been or will be filed, or that an investigation is underway, where doing so could prejudice it. The prohibition protects the integrity of the reporting system and the work of the Financial Intelligence Unit.

Breaching the tipping-off rule can attract criminal liability, including imprisonment and fines, in addition to any administrative penalties the supervisor imposes. The executive regulations reinforce the prohibition and provide protection from liability for those who report in good faith. To stay compliant, firms should limit internal knowledge of a report to those who need it, avoid alerting the client through changes in service, and route all suspicion through the compliance officer. Good-faith reporting itself does not breach any confidentiality duty. Building the prohibition into staff training and internal handling procedures is the most reliable way to prevent an inadvertent tip off through a casual comment or a sudden change in how the client is served.

Legal Reference (UAE):

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

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Tipping off is a criminal offence. Any person who notifies or warns another, or discloses information about transactions under review concerning suspicious transactions, or reveals that the competent authorities are making inquiries or investigating, is punished by imprisonment and a fine of not less than AED 50,000, or by either penalty.

The prohibition binds the firm and its directors, officers and employees, and covers disclosure to the client or any other person that a report has been or is about to be submitted, any related data, or the existence of an investigation. One carve-out is specific to legal professionals: an attempt by a lawyer, notary, other independent legal professional or independent statutory auditor to dissuade a client from committing an unlawful act does not constitute disclosure. Administrative penalties under Article 17 may also follow, and where a legal person is convicted the fine runs from AED 200,000 to AED 10,000,000.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 29(1): imprisonment and a fine of not less than AED 50,000 for tipping off; Article 27(2): the legal person fine.

· Cabinet Resolution No. 134 of 2025, Article 19(1) and (2): the scope of the prohibition and the dissuasion carve-out for legal professionals.

For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.

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