(AML-CFT Law Articles 9.1, 15, 24; AML-CFT Decision Articles 13.2, 17.1, 20.2)

FIs are obliged to report transactions to the FIU without delay when there are suspicions, or reasonable grounds to suspect, that the proceeds are related to a crime, or to the attempt or intention to use funds or proceeds for the purpose of committing, concealing or benefitting from a crime. There is no minimum reporting threshold; all suspicious transactions, including attempted transactions, should be reported regardless of the amount of the transaction. There is also no statute of limitations with regard to when the possible crimes or the suspicious transaction took place.

Under federal law and regulations, whether the FI operates in the mainland UAE or in a Financial or Commercial Free Zone, the designated Competent Authority for the reporting of suspicious transactions is the FIU.

Failure to – immediately - report a suspicious transaction, whether intentionally or by gross negligence, is a federal crime. Any person, including FIs or their managers and employees, who fails to perform their statutory obligation to report a suspicion of money laundering, or the financing of terrorism or of illegal organisations, is liable to a fine of no less than AED100,000 and no more than AED1,000,000 and/or imprisonment.

There are no exemptions from the statutory reporting requirement provided for FIs under the AML-CFT Law or AML-CFT Cabinet Decision.