4.6. Summary of Review, Investigation, and Reporting Timelines
Effective from 3/8/2022The following table summarizes the recommended suspicious activity review, investigation, and reporting timelines in the absence of escalation for expedited review. Please note – the following table captures the maximum timeline by which LFIs should identify and report suspicious activity and transactions. LFIs are ultimately responsible under UAE’s AML-CFT Law to report suspicious activity without delay and should seek to file STRs and SARs ahead of the below timelines.
| Action | Maximum Timeline in Calendar Days |
| Dispositioning of alert; recommendation on whether to file an STR or SAR; and decision on whether to file an STR or SAR | LFIs are expected to file an STR/SAR within a maximum of 35 business days from the date of automated alert generation. |
| Filing of a follow-up STR or SAR for a “complex investigation” | If an LFI designates an investigation as “complex”, the LFI should submit an initial STR within 15 business days of alert generation – SAR/STR to be labelled “Complex investigation”. Followup SAR/STR to be submitted within 30 business days of filing the initial STR. |
| Filing of STR or SAR on continuing activity | Upon filing an STR/SAR pertaining to an account holder, LFIs are expected to implement enhanced monitoring on such account holders. In the case of continued suspicious activity detected against said account holder, LFIs are expected to expeditiously file an STR/SAR continuing activity with the FIU. |