STR & SAR Reporting
Suspicious Reports: Is Your Firm Filing Them Correctly?
Under Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, every DNFBP registered on goAML – including real estate brokerages – is legally required to submit Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) through the FIU’s goAML portal where reasonable grounds for suspicion arise.
Who Must Report
- All UAE mainland and commercial free zone DNFBPs already registered on goAML
- Real Estate Agents & Brokers who are handling property transactions
- Reporting is mandatory where reasonable grounds for suspicion arise – not optional or discretionary
What the Process Involves
Suspicious Transaction Report (STR)
- File when a transaction – completed or in progress – relates to money laundering (ML), terrorism financing (TF), or proliferation financing (PF)
- Trigger point: either at the time of establishing a business relationship or during an actual transaction
Suspicious Activity Report (SAR)
- File when suspicious activity or an attempted transaction relates to ML, TF, or PF
- Trigger point: covers activity that doesn’t reach the transaction stage, including attempts that were never completed
How AML360 Handles It For You
- Confirm which report type applies to each transaction or activity you flag
- Review the quality of every STR/SAR before submission to ensure reports meet FIU expectations and regulatory standards
- Assist the MLRO/Compliance Officer in filing SAR/STR reports on the goAML portal
- Maintain internal documentation and audit trail for every filing
- Train your MLRO/Compliance Officer and staff to recognise red flags & typologies across STRs and SARs
- Assist MLRO/Compliance Officer on any follow-up queries tied to a filed report from MOET and the FIU
- Keep your filing history organised and ready for inspection
The Cost of Non-Compliance
| Risk | Detail |
| Failure to Report (STR/SAR) | AED 100,000 – AED 500,000 per violation (Cabinet Resolution No. 71 of 2024, Violation 22) |
| Tipping Off | Imprisonment (minimum 6 months) and/or a fine of AED 100,000 – AED 500,000 (Article 29, Federal Decree-Law No. 10 of 2025, per the DNFBP Guidelines, March 2026) |
| Repeat Violation | Fine doubled by the supervisory authority (Article 5(2), Cabinet Resolution No. 71 of 2024) |
| Inspection Breach | MOET inspectors review filing history and reporting patterns as part of routine compliance checks (Article 16, Federal Decree-Law No. 10 of 2025) |
| License Action | Non-compliance can escalate to license suspension or revocation (Article 17, Federal Decree-Law No. 10 of 2025) |
Meet Your STR/SAR Reporting Obligations
Suspicious reporting isn’t just a formality – it’s a legal obligation under Federal Decree-Law No. 10 of 2025. AML360 manages your STRs and SARs end-to-end, helping ensure reports are complete, accurate, and submitted in accordance with applicable regulatory requirements.
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