4.4. Suspicious Transaction Report Filing

Effective from 7/6/2021

As required by Article 15 of AML-CFT Law and Article 17 of AML-CFT Decision, LFIs must file a Suspicious Transaction Report (STR) with the UAE Financial Intelligence Unit (UAE FIU) when they have reasonable grounds to suspect that a transaction, attempted transaction, or certain funds constitute, in whole or in part, the proceeds of crime, is related to a crime, or is intended to be used in a crime. 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. By filing STRs with the UAE FIU, LFIs alert law enforcement about suspicious behaviour and allow investigators to piece together transactions occurring across multiple LFIs.

In addition to the requirement to file an STR when an LFI suspects that a transaction or funds are linked to a crime, LFIs should consider filing an STR in the following situations involving legal persons or arrangements:

	•	A potential legal person or arrangement customer decides against opening an account or purchasing other financial services after learning about the LFI’s CDD requirements;
	•	A current legal person or customer cannot provide required information about its business or its beneficial owners;
	•	A legal person or arrangement customer cannot adequately explain transactions, provide supporting documents such as invoices, or provide satisfactory information about its counterparty;
	•	The LFI is not confident, after completing CDD procedures, that it has in fact identified the individuals owning or controlling the legal person or arrangement. In such cases, the LFI should not establish the business relationship, or continue an existing business relationship, and should also consider filing an STR.

Please consult the CBUAE’s Guidance on Suspicious Transaction Reporting for further information.