What penalties apply if a UAE real estate broker fails to file a Suspicious Transaction Report?
Failure to file a Suspicious Transaction Report (STR) is one of the most serious AML violations a UAE real estate broker can commit. The Ministry of Economy and Tourism can impose administrative fines from AED 100,000 up to AED 500,000 for each individual STR-filing failure, and may add a sector ban, suspension of management, restriction or cancellation of the trade licence and closure of the premises.
In parallel, the new AML Law makes STR-filing failure a criminal offence. A person responsible for the failure to inform the FIU of a suspicious transaction faces imprisonment together with a fine of AED 100,000 to AED 1,000,000. Where the failure occurs through gross negligence, the same penalties apply. Tipping off the customer or any third party that an STR has been filed is a separate offence carrying its own fines and imprisonment. Brokers should therefore document every internal escalation, the rationale for filing or not filing, and the date and reference of the goAML submission.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 18 imposes the STR-filing duty; Article 24 prohibits tipping-off; Article 28 sets the criminal penalty for STR failure.
- Cabinet Resolution No. 71 of 2024, Item 22 sets the administrative fine range for STR failure at AED 100,000 to AED 500,000.
For more details, consult the full text of Federal Decree-Law 10 of 2025