Reporting of Suspicious Transactions and/or Activities 

The requirement to lodge a Suspicious Transactions Report and/or Suspicious Activity Reports (STR/SAR) with the Financial Intelligence Unit (FIU) of the Central Bank of the UAE is contained in UAE Federal Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019 (‘Federal AML Legislation’). This Federal AML Legislation applies directly in the DIFC pursuant to Article 70 and 71 of the Regulatory Law 2004.

The FIU reporting mechanism of all suspicious transactions or activities electronically to the FIU using the “GoAML” portal. Registration on the GoAML portal is mandatory for all Relevant Persons.

The implementation of the GoAML system is intended to enable the FIU to:

  • Strengthen and broaden its capability to meet and discharge its legislative objectives and functions;
  • Ensure that the UAE’s financial system stays relevant and effective in the fight against money laundering and terrorism financing;
  • Collaborate more effectively with various stakeholders such as reporting entities, supervisory bodies and law enforcement agencies; and
  • Standardise and streamline all reporting requirements and ensure that the UAE is aligned with the Anti-Money Laundering and Combatting of Terrorist Financing AML/CTF standards of the Financial Action Task Force (FATF).

The DFSA, in its capacity as sole administrator of AML/CTF and sanctions compliance regulation in the DIFC, was entrusted as the Supervisory Body for accepting: (i) pre-registrations to allow Relevant Persons to gain access to the GoAML portal; and (ii) registrations of all Relevant Persons on the GoAML portal (after completing the pre-registration stage).

Relevant Persons should contact the DFSA via the Supervised Firm Contact Form for further information regarding registration for the GoAML portal.

In addition to the above stated Federal AML Legislation requirements, the AML Module of the DFSA Rulebook also obligates Relevant Persons to notify the DFSA immediately following the submission of a STR/SAR to the FIU.

How to notify the DFSA that a STR/SAR has been filed with the FIU.

Relevant Persons are reminded that the failure to report suspicions of money laundering or terrorist financing may constitute a criminal offence that is punishable under the laws of the UAE.

Compliance with local and International Obligations & Sanctions

The DFSA wishes to emphasise that the particular obligations set out below are not all encompassing. It is the responsibility of each Relevant Person to ascertain and assess the relevant international obligations to which they are subject.

UN Security Council Resolutions

As a member state of the United Nations (UN), the United Arab Emirates is committed to implementing the UN Security Council Resolutions (UNSCRs).

Pursuant to Article 19 of Cabinet Resolution No 20 of 2019, Financial Institutions and DNFBPs are required to:

  • Update the details of those included under the Sanctions Committee’s lists on a daily basis by directly referring to the UN-approved resolutions posted on their official website or the UAE Committee for Goods & Material Subject to Import & Export (Executive Office) website.
  • Constantly check client databases and any information obtained in relation to potential or existing clients and compare them with the names included under the Sanctions List, and maintain an updated database of individuals and organisations included in the List.
  • Promptly notify the DFSA, when undertaking asset freezing within five working days from the date of being requested to take freezing measures.
  • Notify the DFSA should it become established that a former client or any occasional client they have dealt with is a person or organisation included under the Sanctions List.
  • Notify the DFSA when no measures are taken due to name similarity and when such similarity could not be eliminated through information available or possible to obtain.
  • Cancel freezing measures within five working days from the date of the cancellation order, and provide DFSA with all related information.

Relevant Persons can subscribe to receive updates on the UNSC Consolidated List from the Executive Office website.

UAE’s list of Terrorist Individuals and Entities

The UAE Government maintains a list of designated terrorist individuals, organisations and groups (the List) pursuant to the UAE Federal AML/CTF legislation. The List can be found in the UAE’s Federal Official Gazette issued by the Ministry of Justice.

The UAE Government announces changes to the List via the Emirates News Agency (WAM).  Relevant Persons are required to update the details of those included under the Sanctions lists on a daily basis by directly referring to the WAM website or the Executive Office website.

Relevant Persons can subscribe to receive updates on the UAE’s List of Designated Terrorist Organisations and Groups from the Executive Office website.

The FCP Team issue email announcements to all Relevant Persons upon notification of any changes to the List. Relevant Persons can view the DFSA announcements here. 

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