When must an accountant in the UAE file a Suspicious Transaction Report?
An accountant in the UAE classified as a DNFBP must file a Suspicious Transaction Report (STR) without delay whenever they suspect, or have reasonable grounds to suspect, that a transaction or funds represent proceeds of crime, are related to money laundering or terrorism financing, or are intended to be used in such crimes. This obligation applies regardless of the value of the transaction.
Under Article 18 of Federal Decree-Law No. 10 of 2025, reporting entities must notify the Financial Intelligence Unit (FIU) directly with a detailed report containing all available data about the transaction and the relevant parties, submitted via the goAML portal. The law expressly states that confidentiality obligations cannot be invoked as a reason for withholding a report.
The obligation arises at the point the accountant forms a suspicion during client interactions, not only when a transaction has been completed. Red flags that may trigger reporting include unusual cash movements, clients unable to explain the source of funds, rapid transfer of assets between accounts, and inconsistencies between a client’s stated business purpose and actual transaction patterns. An accountant cannot tip off the client that a report is being filed — doing so is itself a criminal offence under UAE law.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 18(1), Reporting obligation for all DNFBPs when suspicion arises, regardless of transaction value
- Federal Decree-Law No. 10 of 2025, Article 18(3), Executive Regulations specify the rules governing STR reporting
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.