Any suspicious transactions need to be reported to the Anti-Money Laundering and Suspicious Cases Unit and the DFSA without delay:
Central Bank of the UAE
Anti-Money Laundering Suspicious Cases Unit (AMLSCU)
PO Box 854
Abu Dhabi
UAE
Tel: +971 2 666 8496
cbuaeamlscu@cbuae.gov.ae
1. What is a Suspicious Transaction Report (STR)?
Article 7 of the UAE Federal Law No (4) of 2002 regarding Criminalisation of Money Laundering facilitated the establishment within the UAE Central Bank of a Financial Information Unit, this Unit is called the Anti-Money Laundering and Suspicious Cases Unit (AMLSCU). The same article creates an obligation on all Financial Institutions to report suspicious transactions to the AMLSCU. These reports are known as STRs.
The obligation to report to the AMLSCU is not restricted only to suspicious transactions. Firms should interpret this obligation broadly to include:
• Any suspicious transactions;
• Any attempted suspicious transactions; and
• Any suspicious activity or behaviour, including the actions of customer or potential customers.
STRs should be submitted using the approved STR form and include the following:
• All information that supports your STR;
• Any additional information which would help the AMLSCU to further its investigations; and
• Any additional information which could link the STR to other STRs and other investigations if possible.
Information contained in an STR is confidential and Article 20 of the UAE Federal Law No (4) of 2002, provides Firms with a protection from any criminal, civil or administrative liability which may result from providing the required information in an STR submitted in good faith.
Following the STR submission a Firm will often have on-going dialogue with the AMLSCU as the investigation continues and more information may be requested. The AMLSCU will provide the Firm with a final outcome when a conclusion is reached.
Under Article 15 UAE Federal Law No (4) of 2002, senior management and employees within a Firm who are aware of a suspicious activity, transaction or an attempt, and fail to report an STR may be committing a criminal offence punishable by a fine or imprisonment or both.
Once a Firm has submitted an STR, it must not inform or tipoff the subject of the STR that a report has been lodged. Tipping Off is an offence created by Article 16 of the UAE Federal Law No (4) of 2002 and is punishable by a fine or imprisonment or both.
2. Where can I find the STR form?
Please click here for the soft copy (Word version) of the STR Form that can be filled in and completed.
Please click here for a copy of the STR Form as per the UAE AML Laws. The STR Form can be located on the last page of this document - page 26.
3. Best practices when submitting an STR?
Please click here to view a sample STR form and how to respond to each section.
Please consider the following “Do’s and Don’ts” when submitting an STR:
DO:
Do submit all supporting documentation with your STR
Do submit an STR for suspicious behaviour only i.e. no transaction required
Do provide a soft copy STR form, rather than submitting a handwritten STR
Do submit an STR within a reasonable timeframe of identified suspicious
Do include all relevant details in your STR including source of funds, linked accounts, etc.
Do report confidentially without involving unrelated people as it could alert the customer and be considered as “Tipping Off”
Do maintain your STRs as per the record keeping requirements
Do send additional STRs when further information comes to light in order to supplement the original suspicion. Please ensure that you make references to previous submissions
Do provide your contact details so that the AMLSCU can contact you with follow up questions
Do provide a clear trail of your cause for suspicions and as much detail as possible about the person(s) involved.
DO NOT:
Do not terminate the relationship intentionally prior or post raising the STR unless there is a logical and/or unavoidable reason behind such action. Please wait for an official response from the AMLSCU
Do not insert “refer to documents attached” under “Source of Suspicion.” A brief explanation in the space provided is required and identify the suspicion clearly and concisely.
4. Ideal STR submission process:
*This graph is a simple representation of the process.
