2.3.2 STR Reporting
Effective from 15/8/2021As required by Article 15 of AML-CFT Law and Article 17 of AML-CFT Decision, LFIs must file an STR, or SAR or other report types with the 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 are essential to assist concerned UAE authorities, such as 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:
| • | 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; | |||||
| • | 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; or | |||||
| • | If the LFI believes that a customer may be acting as an unregistered hawaladar. | |||||
Please see also the CBUAE's Guidance for LFIs on Suspicious Transaction Reporting for further information.