What is tipping off under UAE AML law and what are the penalties?
Tipping off is the act of warning or informing a customer or any third party, directly or indirectly, that a suspicious transaction report has been or is about to be filed, or that transactions are under review or that authorities are investigating. Under UAE law, all information relating to suspicious transactions is confidential, and disclosing it defeats the purpose of the reporting regime by allowing suspects to move funds or destroy evidence.
The prohibition binds reporting entities and their directors, officers, and employees. A lapse in confidentiality that lets the customer learn of a report can amount to tipping off. Firms are expected to build strict internal controls, restricted access, and staff training to prevent both deliberate and negligent disclosures.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 29(1) - imposes imprisonment and/or a fine of not less than AED 50,000 for disclosing information on transactions under review; Article 29(3) raises this to imprisonment of not less than one year and a fine equal to the value of the proceeds (minimum AED 100,000) where the disclosure prevents seizure of the proceeds.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 19 - prohibits disclosing to the customer that an STR has been or will be submitted.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.