Suspicious Transaction Report (STR) Services
Suspicious Transaction Report (STR) Services
RH & Hale Law Firm offers professional Suspicious Transaction Report (STR) filing support in Dubai and the UAE. We assist financial institutions, Designated Non-Financial Businesses and Professions (DNFBPs), law firms, real estate businesses, corporate service providers, and other regulated entities in preparing and filing accurate Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) via the official goAML portal to the UAE Financial Intelligence Unit (UAE FIU).
Timely and accurate STR filing is a mandatory legal obligation under UAE AML/CFT laws. Our lawyers and AML compliance specialists provide confidential, regulator-ready support to ensure your compliance obligations are met promptly and help you avoid legal, financial and reputational exposure.
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What Is a Suspicious Transaction Report (STR)?
A Suspicious Transaction Report (STR) is a report submitted to the UAE FIU when a business has reasonable grounds to suspect that a transaction, attempted transaction, or funds may be connected to the financing of money laundering, terrorism, proliferation financing or any other crime. There is no minimum value threshold. Even attempts or unfinished transactions must be reported if there is suspicion of wrongdoing.
STRs (and SARs for suspicious activities) are submitted exclusively via the goAML system run by the UAE FIU. High quality STRs help the authorities to prevent and disrupt financial crime, while preserving the good standing of the UAE financial system.
Legal Framework for STR Filing in the UAE
The requisite for submitting Suspicious Transaction Reports (STRs) in the UAE is fundamentally based on provisions in the UAE’s anti-money laundering and counter-terrorist financing laws, including:
- Federal Decree-Law No. 10 of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (replacing earlier legislation, including Federal Decree-Law No. 20 of 2018 as amended).
- Related Cabinet Decisions and Executive Regulations under Cabinet Decision No. 134 of 2025.
- Guidance and rulebook requirements from the Central Bank of the UAE (CBUAE) for all Licensed Financial Institutions.
- Supervisory requirements applicable to DNFBPs set by the Ministry of Economy and other relevant authorities.
- goAML reporting rules set by the UAE FIU.
Reporting entities are required to file reports “without delay” once reasonable grounds for suspension are confirmed. Tipping-off (i.e. informing the customer that a report has been or is going to be filed) is also not allowed and can attract liability. Generally, records for the STRs should be kept for at least five years.
Who has to file STRs in the UAE?
All entities that have to file STRs are:
- Licensed Financial Institutions (LFIs), including banks, exchange houses, insurance agencies, finance companies, payment service providers and other entities supervised by the CBUAE, SCA, DFSA or FSRA.
- Designated Non-Financial Businesses and Professions (DNFBPs), such as real estate brokers and developers, dealers in metals and stones, independent accountants and auditors, lawyers and notaries (in covered activities), corporate service providers and virtual asset service providers.
- Other regulated entities that have to register to goAML.
All entities should register with goAML regardless of whether they had filed an STR before.
When Should an STR Be Filed?
File an STR as soon as you have reasonable grounds to suspect that funds or a transaction (old or new, completed or attempted) are connected to the commission of a crime.
Examples of possible triggers include:
- unusual transaction patterns,
- inconsistent customer profiles,
- inability to explain source of funds or
- beneficial ownership,
- links to high-risk jurisdictions,
- structuring, or
- Other red flags identified through customer due diligence and ongoing monitoring.
An internal investigation and escalation process must be concluded and analysed as quickly as possible. Defensive or incomplete STR/SAR filing is not recommended and any filing must mention the grounds for suspicion clearly.
Our STR Filing Support Services
At RH and Hale Law firm, we provide seamless, confidential support specifically designed for your sector and risk profile:
- goAML registration and account set up
- Assistance in determining and assessing whether to report a transaction or activity
- Internal investigation support and risk-based review of red flags
- Preparation of clear, comprehensive, regulator ready STR/SAR narratives (who, what, when, where, why and how)
- Preparation of supporting documents and completion of mandatory fields
- Support with safe filing via goAML
- Follow up on Additional Information File (AIF) / or other FIU requests
- AML advisory work including: policy and procedure review, MLRO assistance and staff awareness training on red flags and escalations
- Advice on continued monitoring of compliance as and where needed.
We prioritise accuracy, confidentiality and adequate time to take the necessary actions so your reports are processed in line with the expectations of the UAE FIU.
Step-by-Step STR Filing Process We Support
- Confirm goAML registration and appoint or assist your Money Laundering Reporting Officer (MLRO)/compliance officer.
- Identify and internally escalate suspicious activity via the appropriate channels.
- Conduct an internal proportional review and gather supporting records (customer info, transaction details, contracts, bank statements, correspondence, etc.)
- Prepare a full STR/SAR with a clear narrative of the grounds for suspicion.
- Submit the report to goAML and get the acknowledgment.
- Maintain full records and respond promptly to any subsequent FIU requests.
- Monitor on an ongoing basis and update internal controls as necessary.
Benefits of Professional STR Filing Support
- Full compliance with the current UAE AML/CFT laws and FIU requirements.
- Lower risk of administrative fines, licence implications and criminal exposure due to late, incomplete or missing reporting.
- Safeguarding of business reputation and banking relationships.
- Experienced legal team to handle complex and/or sensitive issues.
- Confidential handling of sensitive information.
- Practical advice that strengthens your overall AML controls.
Consequences of Non-Compliance
Type of Penalty | Applicable To | Penalty Details |
Criminal (Failure to report STR) | Any person (managers, employees, MLRO) | Imprisonment and/or fine of AED 100,000 – 1,000,000 |
Administrative | FIs, DNFBPs, VASPs |
|
Corporate (Legal Persons) | Companies / entities | Administrative fine up to AED 5,000,000; or AED 5m – 100m (or value of criminal property) for ML/TF/PF offences |
Tipping-off | Any person | Imprisonment and/or fine of not less than AED 50,000 |
In recent years, regulators have been focusing on the quality of submissions and the reasons given for non-filing of reports.
Why RH & Hale Law Firm for your STR filing needs in Dubai?
At RH & Hale Law Firm, a Dubai-based law firm, our AML Compliance experts:
- Combine knowledge of UAE federal AML legislation, free zone regulation (where applicable DIFC and ADGM) and practical experience in goAML processes.
- We understand the specific challenges faced by DNFBPs and financial institutions operating in Dubai and the wider UAE.
- Our work is discreet, accurate and focused on protecting both your compliance status and commercial interests.
- We provide clear legal and compliance support to our clients in mainland Dubai, free zones and other Emirates.
Contact RH & Hale Law Firm for STR Filing Support
If you require goAML registration, STR/SAR filing or general AML/CFT compliance filings in Dubai and the UAE, contact our team for confidential advice.
Safeguard your business, meet your obligations, and contribute to a safer financial system with expert support from RH & Hale for filing Suspicious Transaction Reports.
FAQs – Suspicious Transaction Report
What is a Suspicious Transaction Report (STR) in the UAE?
There are a lot of factors that affect the overall duration it takes to complete an arbitration process, including:
- Complexity of your case.
- Effectiveness of the arbitration procedure.
- Expertise of lawyers.
On average, you can expect an arbitration process to last for a few months to up to a year in UAE. However, this is a faster process when compared to the jurisdictional formalities.
Who is required to submit a Suspicious Transaction Report in the UAE?
Regulated entities and reporting organisations, including financial institutions, banks, exchange houses, auditors, and certain Designated Non-Financial Businesses and Professions (DNFBPs), must report suspicious transactions in accordance with applicable UAE AML regulations.
When should a business file an STR in the UAE?
An STR should be submitted promptly when a reporting entity identifies reasonable grounds to suspect that a transaction or attempted transaction may be linked to criminal activity. Businesses should follow the applicable reporting requirements and avoid unnecessary delays.
What information is required to file an STR in the UAE?
An STR generally requires details about the customer, transaction, parties involved, the reason for suspicion, supporting documents, and relevant financial records. Accurate and complete information helps the authorities assess the reported activity.
How can professional STR services help businesses in the UAE?
Professional STR services can help businesses assess suspicious activities, prepare supporting documentation, follow applicable AML reporting procedures, and submit reports through the appropriate channels. They can also support AML compliance reviews and help strengthen internal reporting processes.