If a financial institution suspects that a transaction involves proceeds of crime, what must it...

The UAE AML framework requires immediate escalation when a financial institution has suspicions or reasonable grounds to suspect that a transaction, attempted transaction or funds represent proceeds of crime, relate to criminal activity or are intended to be used in a crime. The report must be made directly to the UAE Financial Intelligence Unit (FIU), rather than to the Securities and Commodities Authority, and it must be submitted without delay. The reporting institution cannot postpone submission for one week or rely on banking, professional or contractual confidentiality to avoid its reporting obligation. The FIU receives and analyses suspicious transaction reports and may request additional information from the reporting institution. The rules also apply irrespective of the monetary value of the transaction; there is no minimum threshold before the reporting obligation arises. Current UAE implementing provisions continue to require immediate and direct reporting to the FIU through its approved electronic reporting system. Accordingly, option C correctly identifies both the competent recipient—the Financial Intelligence Unit—and the required timing—without delay.

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