1.3.1. Consequences for Failure to Disclose Suspicious Activity
Effective from 7/6/2021Failure to report a suspicious transaction (STR, SAR, or other report types) without delay, whether intentionally or by gross negligence, is a federal crime in the UAE. The AML-CFT Law provides for the following sanctions against any person, including an LFI, or their managers and employees, who fail to perform, whether purposely or through gross negligence, their statutory obligation to report a suspicion of money laundering and related predicate offences or the financing of terrorism or of illegal organisations:
| • | Imprisonment and fine of no less than AED100,000 and no more than AED1,000,000; or | |||
| • | Any of these two sanctions (i.e., imprisonment or fine of no less than AED100,000 and no more than AED1,000,000), according to Article 24 of the AML-CFT Law. | |||
According to Article 15 of the AML-CFT Law, the requirement to report is in the case of suspicion or reasonable grounds to suspect a crime.