Common Offences
In a Nutshell
- Common offences are predicate crimes that generate illicit proceeds that may become the subject of money laundering; they are derived from the definition of a Predicate Offence defined under Article 1 of Federal Decree-Law No. 10 of 2025.
- The STR obligation for common offence patterns arises from suspicion alone, with no threshold; sub-threshold structuring across multiple accounts is as reportable as a single large transaction.
- The STR and SAR are the applicable goAML report types; common offences do not trigger DPMSR, REAR, HRC, or HRCA unless the specific sector conditions for those reports are independently met.
- Network-level monitoring is required to detect common offence patterns; account-level monitoring calibrated only for high-value transactions will systematically miss them.
- Channel risk is the defining risk dimension: cash-intensive businesses, peer-to-peer payment platforms, and IVTS operators are the three common channels.
Common offences generate illicit proceeds that enter the financial system through the same channels that serve millions of legitimate customers every day. Detecting them and meeting the STR filing obligation on goAML requires compliance programmes that look beyond individual transactions to the patterns that emerge when multiple accounts, channels, and actors are assessed together.
What Common Offences Are and Why They Require goAML Reporting
Article 1 of Federal Decree-Law No. 10 of 2025 defines a Predicate Offence as any crime whose proceeds form the object of a money laundering offence. Common offences are a commonly used AML typology describing street-level predicate crimes such as petty drug trafficking, gang-affiliated cash schemes, unlicensed remittance operations, and coordinated structuring by organised crime groups.
Article 2 of the same Decree-Law confirms that money laundering is an independent offence; a prior conviction for the underlying common offence is not required before a money laundering charge can be brought. This means that a compliance team identifying proceeds of apparent common criminal activity in a customer’s account is facing a live reporting obligation regardless of whether law enforcement has already identified the underlying crime.
Under Article 18 of Cabinet Resolution No. 134 of 2025, regulated entities are required to file an STR via the goAML platform without delay when there is a reasonable suspicion that a transaction involves money laundering or terrorism financing proceeds. For common offence patterns, that suspicion typically arises not from a single transaction but from an aggregate pattern identified across a review period.
Applicable goAML Report Types: STR and SAR
The applicable goAML report types for common offence activity are the Suspicious Transaction Report (STR) and the Suspicious Activity Report (SAR). Common offences do not independently trigger DPMSR, REAR, HRC, or HRCA. Those report types have specific sector-based or jurisdiction-based triggers that are independent of the common offences typology. If common offence proceeds happen to involve a DPMS dealer, a real estate transaction, or movement to or from a FATF High-Risk Jurisdictions subject to a Call for Action, the relevant specialist report type may also apply alongside the STR, but the STR obligation arises first from the suspicious activity itself.
The STR is filed when a completed or attempted transaction involving the proceeds of common criminal activity creates reasonable suspicion. The SAR is filed when suspicious behaviour, such as a customer presenting currency in denominations consistent with street-level drug proceeds, or making multiple cash deposits at different branches on the same day, creates suspicion independently of whether a specific completed transaction is the trigger.
Need Help With Common Offences STR Filing?
When suspicious activity points to common offence proceeds, the reporting obligation can arise without delay. Make sure your goAML process is ready.
Why Sub-Threshold Structuring Is Fully Reportable
Common offence networks deliberately keep individual transaction values small to avoid triggering monitoring thresholds. A street-level drug operation generating AED 5,000 per day across five participants will deposit AED 1,000 each, none of which is large enough to trigger a single-transaction rule. Over three months, those five accounts collectively processed AED 450,000.
The STR obligation under Article 18 of Cabinet Resolution No. 134 of 2025 arises from suspicion, not from a threshold being exceeded. A pattern of coordinated sub-threshold deposits across five accounts sharing counterparties and deposit timing creates the obligation to report without delay. Filing the STR requires the compliance team to have monitoring capabilities that identify the pattern across accounts, not just within individual account transaction histories.
Channel Risk: The Three Primary Channels for Common Offence Proceeds
Cabinet Resolution No. 134 of 2025, Article 5 requires enterprise-wide risk assessments to incorporate channel-level risk from predicate crime exposure. For common offences, the three commonly observed channels are:
Cash-Intensive Business Accounts
The cash-intensive business provides a commercial rationale for high-volume cash deposits. The institution sees aggregate deposits and must determine whether the declared revenue is plausible for a business of that type, size, and location. STR consideration is triggered when declared revenue cannot be reconciled with observable business activity.
Peer-to-Peer Payment Platforms
P2P platforms process high volumes of small-value payments that are individually indistinguishable from ordinary consumer transactions. Criminal networks use multiple participant accounts to aggregate small credits into large balances, which are then consolidated. Detection requires network-level monitoring of shared counterparties and coordinated payment timing.
Informal Value Transfer System Operators
IVTS operators accept domestic cash and settle equivalent value internationally without funds crossing a border through the formal banking system. An unregistered IVTS account accepting cash from multiple sources with no documented business purpose is a significant red-flag indicator associated with common offence typologies.
Want Stronger Controls for Predicate Offence Exposure?
Common offences sit at the intersection of channel risk, structuring, and suspicious activity reporting. Build a more resilient compliance response.
Key STR Filing Indicators for Common Offence Patterns
← scroll to see full table →
| Observable Pattern | STR Filing Assessment |
|---|---|
| Multiple sub-threshold cash deposits at the same branch on the same day by related account holders | Strong indicator of coordinated structuring; STR should be filed on the aggregate pattern |
| Cash-intensive business deposits are escalating beyond sector benchmarks without an operational explanation | Source-of-funds inconsistency; STR consideration required |
| P2P credits from a large set of counterparties aggregating to an amount inconsistent with declared income | Network-level suspicious activity; SAR or STR, depending on whether a completed transaction is the trigger |
| Account receiving inward value transfers, then making outbound payments to a single consolidating account | Smurfing or IVTS-associated activity; STR obligation arises from suspicion |
| Unlicensed MSB activity identified through cash handling patterns inconsistent with declared business | IVTS/MSB compliance gap; STR and referral to the Central Bank MSB registry verification |
Record Retention and Documentation
Article 25 of Cabinet Resolution No. 134 of 2025 requires all transaction records, CDD files, and STR-related documentation to be retained for a minimum of five years from the end of the business relationship or transaction date. For common offence investigations, the documentation must include the transaction monitoring alerts that identified the pattern, the analysis conducted, and the decision path that led to the STR being filed or not filed.
Register on goAML to Meet Common Offence Reporting Obligations
STRs for common offence patterns must be filed through the goAML platform without delay. Contact goAML Registration for support with STR advisory services and to ensure your monitoring programme is calibrated to detect the low-value, high-frequency patterns that common offence typologies produce.
Need Support Calibrating Common Offences Risk?
If your current controls are geared toward high-value transfers, they may not catch low-value, high-frequency criminal flows. Get a compliance-focused review.
Frequently Asked Questions
Yes, if the aggregate pattern creates reasonable suspicion. The STR obligation under Article 18 of Cabinet Resolution No. 134 of 2025 arises from suspicion, not from any specific monetary threshold. If a pattern of sub-threshold deposits, assessed across a group of related accounts over a defined period, generates reasonable suspicion of money laundering, the institution must file without delay. The absence of any individual transaction above a threshold does not remove the obligation.
Every alert that is reviewed and closed without an STR must have a documented rationale explaining why the available evidence did not reach the reasonable suspicion threshold. This documentation must be retained under the five-year record retention requirement and must be sufficient to demonstrate to a supervisory authority that the decision was made on the basis of a reasoned analysis, not because the alert was dismissed without review.
The STR is the applicable report type for suspicious activity regardless of the channel. There is no separate report type for cash-intensive business account activity. The STR narrative should include all relevant indicators from the account, including the channel characteristics, the specific suspicious patterns, and the analysis of whether the business’s declared activity explains the observed transaction volumes.