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I noticed a suspicious transaction from a client — do I report it, or ask them about it first?

التساؤل

I noticed a suspicious transaction from a client — do I report it, or ask them about it first?

الإجابة

Never ask. The rule is that if you suspect, or have reasonable grounds to suspect, that a transaction or attempted transaction is connected to money laundering or terrorist financing — even if the transaction never actually completed — you must file a Suspicious Transaction Report (STR) via the goAML platform "without delay," regardless of the amount involved. The report goes to the Financial Intelligence Unit (FIU) and is entirely separate from other reporting obligations, such as reporting cash transactions above a set threshold.

What's strictly prohibited is "tipping off": telling the client or any other party that a report has been filed about them, that an investigation is underway, or even hinting at it indirectly. Article 18 of Federal Decree-Law No. 10 of 2025, read together with Articles 17 to 19 of Cabinet Resolution No. 134 of 2025, prohibits this explicitly, and it is a standalone offence separate from the original suspicion itself. In practice, this means continuing to deal with the client normally on the surface while keeping the fact of the report confidential internally, limited to as few staff as necessary. RASEEKH gives clients a clear, practical process for when suspicion crosses the line into a reportable event, and how to act on it without breaching the no-tipping-off rule.

تواصل مباشر

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