Who is responsible for filing suspicious transaction reports in a UAE company?
The legal obligation to report sits with the financial institution, DNFBP, or virtual asset service provider itself under Federal Decree-Law No. 10 of 2025 Article 18, but in practice it is discharged by the appointed AML/CFT compliance officer. Article 19 requires entities to build and maintain a risk-based compliance programme, and the Executive Regulations require a qualified compliance officer with the authority to access information and to file reports independently.
Front-line staff must escalate suspicions internally. The compliance officer reviews them, decides whether reasonable grounds exist, and submits the STR or SAR through goAML without delay. The officer also handles goAML registration, responds to FIU requests, and keeps records. Senior management remains accountable overall and cannot override a proper filing. Concentrating the decision in a trained compliance officer helps ensure consistency, protects the confidentiality of filings, and manages tipping-off risk.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18: the reporting obligation on the entity.
· Federal Decree-Law No. 10 of 2025, Article 19: risk-based compliance programme and controls.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.