In the absence of escalation for expedited review, LFIs are expected to file an STR/SAR within a maximum of 35 business days from the date of automated alert generation. The establishment of adequate grounds of suspicion may involve the investigation procedures as per the LFIs' AML and/or Financial Crime Compliance policies and procedures. LFIs are expected to complete the required investigative procedures as expeditiously as possible. LFIs must maintain adequately detailed records of investigative procedures performed against alerts and when filing an STR/SAR, must include a summary justifying the time taken to establish grounds of suspicion.

In the event of escalation for expedited review, the Compliance Officer or MLRO should file an STR or SAR to the FIU within 24 hours of the determination. All prospective STRs or SARs should be reviewed for accuracy and completeness prior to filing, in accordance with applicable procedures.

LFIs are ultimately responsible under UAE’s AML-CFT Law to report suspicious activity without delay and should seek to file STRs and SARs ahead of the prescribed timeline.