The relevant person must develop and implement policies, procedures, and controls to identify and report suspicious activities or transactions related to potential money laundering (ML) and terrorism financing (TF). The suspicious activity report (SAR) or suspicious transaction report (STR) should be filed with the Financial Intelligence Unit (FIU), followed by a notification of such reporting to the Dubai Financial Services Authority (DFSA).

This Practice Note will provide an overview of SAR or STR filing along with best practices the relevant person should adopt to ensure complete and accurate filing of the reports with the FIU. Moreover, this Practice Note also provides certain examples to help identify whether a SAR or STR is to be reported.

• AML: Anti-money laundering.

• Authorised person: Authorised firm or an authorised market institution.

• Authorised firm: An authorised person who holds a licence to carry on one or more financial services in or from the DIFC and is not an authorised market institution.

• Authorised market institution: An authorised person operating an exchange, a clearing house or an alternative trading system.

• Beneficial owner: A beneficial owner includes the following: