What is the penalty for failing to file a suspicious transaction report in the UAE?
Failing to file a suspicious transaction report when required is a serious offence in the UAE, not a mere administrative lapse. A person who, deliberately or through gross negligence, breaches the reporting obligation faces imprisonment and a fine of not less than AED 100,000 and not more than AED 1,000,000, or either penalty. This criminal exposure attaches to the failure to report a transaction or funds suspected of being linked to a crime.
Separately, the supervisory authority can impose administrative penalties on the entity for breaching its AML obligations, ranging from a warning to fines of up to AED 5,000,000 per violation, restrictions on the business, and ultimately licence revocation. These administrative and criminal consequences can apply together. The message for reporting entities is that a robust process for identifying, escalating, and promptly filing suspicious transaction reports is essential to avoid liability for both the firm and responsible individuals.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 28 - imposes imprisonment and a fine of AED 100,000 to AED 1,000,000 for violating the Article 18 reporting obligation.
· Federal Decree-Law No. 10 of 2025, Article 17 - allows administrative fines of AED 10,000 to AED 5,000,000 per violation and other measures.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.