AML/CFT UAE: How to Detect and Report Suspicious Transactions/Activities

Financial crimes like money laundering and financing of terrorism are a significant threat to every country’s stability. In the UAE, these risks are especially serious because of its fast-growing economy and global connections. When suspicious transactions go unnoticed, criminals can hide their money and fund illegal activities that harm communities and damage trust in the financial system.

The solution lies in awareness, timely detection, and proper reporting. UAE authorities have built a clear structure to help financial institutions, DNFBPs, and Virtual Asset Service Providers (VASPs) identify and report suspicious activities through the designated channels established by UAE regulatory authorities.

Jitendra Chartered Accountants (JCA) helps businesses report suspicious activities and ensure compliance with AML/CFT laws. Our AML consultants in the UAE assist businesses with comprehensive risk assessments to help mitigate money laundering and terrorism financing (ML/FT) risks..

 Recognising Suspicious Activity in the UAE

Suspicious activity is any transaction or behaviour that seems unusual compared to a customer’s normal dealings. Employees are the first line of defence because they interact directly with clients and handle daily operations.

Some warning signs that may indicate money laundering or terrorism financing include:

• Customers who make unusually large transactions that do not align with their known financial profile.
• Transactions linked to high-risk jurisdictions or individuals with criminal records.
• Refusal to provide identity documents or reluctance to disclose beneficial ownership.
• Use of fake or forged identity documents.
• Complex business structures without a clear commercial reason.
• Payments made from unrelated third-party accounts.

Employees should remain vigilant to red flags and promptly report concerns to the AML Compliance Officer or seek guidance from qualified AML consultants in the UAE

The Role of Employees in AML Compliance

Employees are often the first to notice unusual patterns in customer behaviour or transaction activity. To perform this duty effectively, staff must receive proper training on:

• Following the organisation’s internal reporting procedures.
• Knowing who to contact and what details to include in internal reports.
• Maintaining confidentiality throughout the process.

The Role of the AML Compliance Officer

The AML Compliance Officer (CO) oversees all suspicious activity reports (SARs) or suspicious transaction reports (STRs) within the organisation. Their responsibilities include:

• Collecting and reviewing all internal reports from staff.
• Analysing the information to confirm if there is enough reason to suspect financial crime.
• Submitting confirmed reports to the UAE Financial Intelligence Unit (FIU) via the goAML platform.
• Responding promptly to any follow-up requests from the FIU or the Virtual Assets Regulatory Authority (VARA).

The CO ensures that all reports meet regulatory standards and are filed without delay. They also provide regular feedback and refresher training to employees. The role can also be given to professional AML consultants in Dubai.

Ensuring Confidentiality and Protection

Confidentiality is critical when dealing with suspicious transaction reports (STRs) or Suspicious Activity Reports (SARs). Employees must feel safe when reporting concerns. UAE law requires organizations to protect whistleblowers from retaliation or discrimination.

It is also strictly prohibited to “tip off” a customer or third party about a report being filed. Disclosing this information (“tipping off”) is a criminal offence under Federal Decree-Law No. (20) of 2018 and can result in severe penalties, including imprisonment.

Training and Awareness Programs

Training is the backbone of an effective AML program. It should cover:

• The basics of money laundering and terrorism financing.
• Identification of suspicious behaviors.
• Procedures for reporting and record-keeping.
• Real examples of how suspicious activity has been detected in the past.

Ongoing training ensures employees stay up to date with changing regulations and internal policies. Both front-line and back-office staff should participate since suspicious activity can occur in any department. AML consultants in the UAE can help you train your team.

Transaction Monitoring in the UAE

Transaction monitoring helps identify suspicious behaviour by continuously reviewing customer activity. This process is essential for financial institutions and VASPs operating in the UAE.

Under Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019, regulated entities must implement systems that track transactions in real time, identify unusual patterns, and report them immediately.

Modern monitoring systems often combine artificial intelligence and data analytics to spot irregular transactions faster and with greater accuracy. However, human judgment remains vital to interpret alerts and decide whether a report should be submitted.

Reporting to the UAE Financial Intelligence Unit (FIU)

Once a transaction raises suspicion, the AML Compliance Officer must report it to the UAE FIU using the goAML platform. Reports must include:

• Details of the customer and transaction.
• Reasons for suspicion.
• Supporting documents and evidence.

VASPs and financial institutions are also required to continue monitoring the account or transaction after the report is filed. Learn how goAML works in depth from our AML consultants in the UAE.

How can Jitendra Chartered Accountants help?

Through vigilant employees, well-trained AML consultants in the UAE, and timely reporting to the FIU, businesses can safeguard their operations and contribute to a safer financial environment for all. JCA’s expert consultants help you with risk assessments as well as goAML reporting and ensure that you comply with AML/CFT laws in the UAE.