3.4.2. STR Reporting

Effective from 31/10/2022

As required by Article 15 of the AML-CFT Law and Article 17 of AML-CFT Decision, insurance operators must file without any delay an STR or SAR with the UAE FIU when they have reasonable grounds to suspect that a transaction, attempted transaction, or certain 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. STR/SAR 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/SAR filings are essential to assisting law enforcement authorities in detecting criminal actors and preventing the flow of illicit funds through the UAE financial system.

In addition to the requirement to file an STR when an operator suspects that a transaction or funds are linked to a crime, operators should consider filing an STR or SAR in the following situations involving higher-risk customers:

	•	A potential customer decides against purchasing financial services after learning about the operator’s CDD requirements;
	•	A current customer cannot provide required information (including documentation) about its business or its beneficial owners;
	•	A customer cannot adequately explain transactions, provide supporting documents such as invoices, or provide satisfactory information about its counterparty;
	•	The operator is not confident, after completing CDD procedures, that it has in fact identified the individuals owning or controlling the customer. In such cases, the operator should not establish the business relationship, or continue an existing business relationship; or
	•	Other situations that are suspicious or involve activity with no legitimate business or other lawful purpose.

Please consult the CBUAE’s Guidance for Licensed Financial Institutions on Suspicious Transaction Reporting¹² for further information.

¹² Available at: https://www.uaeiec.gov.ae/en-us/un-page.