What must a UAE business do when it suspects a transaction involves money laundering?
When a financial institution, DNFBP or virtual asset service provider suspects, or has reasonable grounds to suspect, that a transaction or funds represent proceeds of crime or are linked to money laundering, terrorist financing or proliferation financing, it must notify the Financial Intelligence Unit without delay and directly. This applies regardless of the value of the transaction.
The notification takes the form of a detailed suspicious transaction report containing all available data on the transaction and the parties involved, filed through the FIU’s electronic system, which in the UAE is the goAML platform. The business must also provide any additional information the Unit requests, and it cannot refuse on the grounds of banking or professional confidentiality.
A narrow exception exists for lawyers, notaries, other legal professionals and independent legal auditors where the information was obtained in circumstances subject to professional secrecy. For everyone else, failing to report, or tipping off the customer that a report has been made, is a criminal offence. Reporting in good faith carries legal protection from liability.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18 requires reporting of suspicious transactions to the FIU without delay, regardless of value and without invoking confidentiality
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.