3.3.2 STR Reporting

Effective from 27/9/2021

As required by Article 15 of the AML-CFT Law and Article 17 of AML-CFT Decision, LFIs must file a suspicious transaction report (“STR”) or suspicious activity report ("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. 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.

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 higher-risk customers:

	•	A potential customer decides against opening an account or purchasing other financial services after learning about the LFI’s CDD requirements;
	•	A current customer cannot provide required information 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; or
	•	The LFI is not confident, after completing CDD procedures, that it has in fact identified the individuals owning or controlling the customer. In such cases, the LFI should not establish the business relationship, or continue an existing business relationship.

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

¹² Available at https://www.centralbank.ae/en/cbuae-amlcft.