The Riffle
The UAE Financial Intelligence Unit (FIU) has issued Regulation No. (1) of 2026, creating a formal framework for the suspension of suspicious transactions, freezing of funds, and monitoring of high-risk activity.
The regulation introduces a new reporting mechanism — the Postponement Suspicious Transaction Report (PSTR) — for situations where funds are at immediate risk of transfer or dissipation. It also grants the FIU authority to issue Suspension Orders, Freezing Orders and Monitoring Orders that Reporting Entities must execute within strict timelines.
The framework applies to financial institutions, Designated Non-Financial Businesses and Professions (DNFBPs), and Virtual Asset Service Providers (VASPs).
Key Highlights
New Postponement Suspicious Transaction Report (PSTR)
Reporting Entities must file a PSTR when they suspect funds may represent the proceeds of crime and there is an imminent risk that those funds could be moved or withdrawn.
Factors that may trigger a PSTR include:
Transactions of AED 500,000 or more
Links to politically exposed persons (PEPs) or other high-risk customers
Concerns that a customer may leave the country
Situations where funds cannot be effectively monitored
The PSTR is an additional reporting requirement and does not replace existing STR obligations.
Transactions May Need to Be Delayed
Where a PSTR is submitted, Reporting Entities are generally expected to refrain from executing the transaction until:
The FIU provides authorisation; or
Three business days pass without FIU communication.
FIU Can Issue Immediate Suspension Orders
The FIU may order a specific transaction to be suspended for up to 10 business days.
Entities must:
Implement the order immediately
Acknowledge receipt within two hours
Avoid any form of tipping-off to customers or third parties
Broader Freezing Powers Introduced
The FIU may also freeze funds, accounts and business relationships for up to 30 days, with the possibility of extension by the Attorney General.
Following execution of a freezing order, entities must notify the customer and obtain supporting information regarding the origin of the funds.
Stronger Compliance Expectations
Reporting Entities are expected to maintain:
24/7 operational readiness
Dedicated compliance oversight
Clear audit trails and recordkeeping
Staff training and escalation procedures
Records for at least five years after the end of the business relationship
Why It Matters
The regulation strengthens the UAE’s AML, CFT and proliferation financing framework by creating a mechanism for rapid intervention where suspicious funds may be at risk of dissipation.
For Reporting Entities, the focus is no longer limited to detecting suspicious activity. Firms must also ensure they have the operational capability to respond to FIU instructions immediately, including outside normal business hours.
Financial institutions, DNFBPs and VASPs should review their reporting procedures, escalation frameworks and compliance resources to ensure they are prepared for the new requirements.
The Riffle Takeaway
Regulation No. (1) of 2026 signals a more proactive approach to financial crime prevention in the UAE. The introduction of the PSTR framework, combined with strict response timelines and expanded freezing powers, raises the bar for compliance readiness. Firms should use the implementation period to assess whether their systems, people and procedures can support the level of responsiveness the FIU now expects.
