All LEH should have procedures and systems in place to ensure that suspicious activity is reported to authorities in an appropriate and timely manner. LEH must take into account all information from both the ordering and beneficiary sides in order to determine whether an STR or SAR is to be filed.

As required by Article 15 of AML-CFT Law and Article 17 of AML-CFT Decision, LEH must file without any delay an STR or SAR or other report types with the FIU using the “goAML” portal 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. Under Article 24 of the AML-CFT Law, any person, including a LEH or their managers and employees, who violates on purpose or by gross negligence their statutory obligation to report a suspicion of money laundering and related predicate offences, financing of terrorism or illegal organisations is liable of the following sanctions:

¹³ Available at: https://www.centralbank.ae/en/cbuae-amlcft