What is the difference between an STR and a SAR in the UAE?
In the UAE, a Suspicious Transaction Report (STR) is filed when a reporting entity suspects that a specific transaction, an attempted transaction, or a movement of funds represents proceeds of crime or is linked to money laundering, terrorist financing, or proliferation financing. The trigger is transactional, meaning there is an identifiable movement or attempted movement of money or value tied to a customer. A Suspicious Activity Report (SAR), by contrast, is filed when the suspicion arises from behaviour, a customer profile inconsistency, or a pattern that has not yet produced a transaction.
Although UAE practitioners often use the two terms interchangeably, the goAML portal of the Financial Intelligence Unit treats them as distinct report types selected at the point of filing. What matters legally is that the obligation to report, without delay and regardless of value, applies to both once reasonable grounds for suspicion exist. Choosing the correct report type helps the FIU triage and analyse the intelligence more effectively.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18 - requires FIs, DNFBPs, and VASPs to notify the FIU without delay where a transaction or funds are suspected to be proceeds of, or related to, a crime.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 18 - extends the reporting duty to attempted transactions and funds, regardless of value.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.