What is the reporting obligation for suspicious transactions in the UAE?
Financial institutions, DNFBPs and virtual asset service providers must report all suspicious transactions to the UAE Financial Intelligence Unit regardless of the amount. A suspicious transaction is one involving funds where there are reasonable grounds to believe they are earned from any misdemeanour or felony, or relate to terrorist financing or financing of illegal organisations, whether committed or attempted.
There is no de minimis threshold. The absence of an amount test is deliberate, because structuring below a threshold is itself one of the typologies the NRA records in the exchange house sector. Attempted transactions are covered as well as completed ones, which means a declined onboarding or an abandoned transfer can still generate a reporting obligation.
Supervisory authorities have a range of disciplinary and financial sanctions available for breach, including the ability to impose penalties on FIs, DNFBPs and VASPs up to and including cancellation of the licence.
Legal Reference (source document and governing law):
· UAE Money Laundering and Terrorist Financing National Risk Assessment, 2nd NRA (2024)
· Federal Decree-Law No. 10 of 2025 on AML/CFT and Financing of Illegal Organisations
· Cabinet Resolution No. 134 of 2025, Executive Regulations
Scope note: reports are filed through the goAML portal. Report types and codes are set by the UAEFIU.
Further reading: Reporting on the goAML portal under UAE AML rules
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