As required by Article 7 of the AML-CFT Decision, LFIs must continuously monitor all their transactions to ensure that the transactions conducted are consistent with the information they have about the customer, their type of activity and the risks they pose, including, when necessary, the source of funds. As with all customer types, LFIs that use automated monitoring systems should apply rules with appropriate thresholds and parameters that are designed to detect common typologies for illicit behaviour. When monitoring and evaluating transactions, the LFI should take into account all information that it has collected as part of CDD.

Monitoring systems can include manual monitoring processes and the use of automated and intelligence led monitoring systems. In all cases, the appropriate type and degree of monitoring should appropriately match the money laundering and financing of terrorism (ML/FT) risks of the institution’s customers, products and services, delivery channels, and geographic exposure, and may therefore vary across an LFI’s business lines or units, where applicable. TM programs should also be calibrated to the size, nature, and complexity of each institution. The transaction monitoring system used by LFIs should be equipped to identify patterns of activity that appear unusual and potentially suspicious for PEPs customers as well as unusual behaviour that may indicate that a customer’s business has changed in such a way as to require a high risk rating. Please consult also the CBUAE’s Guidance for Licensed Financial Institutions on Transaction Monitoring and Sanctions Screening³ for further information.

³ Available at: https://www.centralbank.ae/en/cbuae-amlcft

As required by Article 15 of the AML-CFT Law and Article 17 of AML-CFT Decision, LFIs must file an STR, SAR or other report types with the UAE Financial Intelligence Unit (UAE FIU) when they have reasonable grounds to suspect that a transaction, attempted transaction, or funds constitute, in whole or in part, regardless of the amount, the proceeds of crime, are related to a crime, or are intended to be used in a crime. As per Article 18 of the AML-CFT Decision, In reporting their suspicions, employees must maintain confidentiality with regard to both the information being reported and the act of reporting itself, and make reasonable efforts to ensure the information and data reported are protected from access by any unauthorised person (Please consult also section 7.8 of the CBUAE’s Guidelines on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations for Financial Institutions). STR filing is not simply a legal obligation; it is a critical element of the UAE’s effort to combat financial crime and protect the integrity of its financial system. STR filings assist law enforcement in detecting criminal actors and preventing the flow of illicit funds through the UAE financial system. Please consult also the CBUAE’s Guidance for Licensed Financial Institutions on Suspicious Transaction Reporting⁴ for further information.

⁴ Available at: https://www.centralbank.ae/en/cbuae-amlcft