Suspicious transaction report
A client wants to pay through a third party with no clear reason. Should I report it?
The situation
If you suspect funds may be linked to crime, you must file a suspicious transaction report through goAML without delay, and you must not tell the client.
The law
- Federal Decree-Law 10 of 2025: Duty to report suspicion and prohibition on tipping off
What it means for you
Unexplained third-party payments are a common red flag. Example: a property buyer whose deposit comes from an unrelated foreign company, with no explanation, should be escalated to the compliance officer and reported if the doubt remains. Breaching reporting duties can bring heavy fines and prison terms under the law.
What to do
- Record what makes it suspicious.
- Escalate to the compliance officer.
- File an STR in goAML if suspicion remains.
- Do not tell the client.
We can do this for youAML for DNFBPs: goAML registration, compliance officer, risk assessment, customer checks and reporting: AED 3,500