The anti-money laundering laws of Jordan, the UAE, Qatar and Kuwait require financial institutions and specified non-financial businesses and professions to notify the financial intelligence unit immediately and without delay of any transaction, or attempted transaction, suspected of being linked to money laundering or terrorist financing, regardless of the value of that transaction. Some of these laws exempt lawyers and independent accountants from this duty in situations covered by professional secrecy.
Jordan: Immediate Notification Regardless of Value
Article 18 of Jordan's Anti-Money Laundering and Counter-Terrorist Financing Law provides that a reporting entity must notify the Unit immediately of any transaction, activity or attempt to carry one out, if it suspects, or has reasonable grounds to suspect, that the funds are proceeds of a money laundering offence, a related predicate offence, or terrorist financing, regardless of the value of the transaction.
The UAE: Reporting Without Delay, Including Virtual Asset Providers
The UAE's Federal Decree-Law No. (10) of 2025 requires financial institutions, specified non-financial businesses and professions, and virtual asset service providers, when they suspect or have reasonable grounds to suspect a transaction or funds, to report the Unit without delay and directly, regardless of the value of that transaction. The same article, however, exempts lawyers, notaries public, other members of the legal profession, and independent legal auditors from this duty where the related information was obtained in circumstances covered by professional secrecy.
Qatar: Immediate Reporting of Any Attempted Transaction
Article 21 of Qatar's Anti-Money Laundering and Counter-Terrorist Financing Law provides that financial institutions and specified non-financial businesses and professions must report to the Unit immediately any transaction, operation, or attempt to carry one out, regardless of its value, upon suspicion or the availability of reasonable grounds for suspicion that it is linked to the proceeds of a predicate offence or to terrorist financing.
Kuwait: the General Duty and the Legal-Professional-Privilege Exception
Kuwait's law requires financial institutions and specified non-financial businesses and professions to notify the Unit without delay of any transaction, or attempt to carry one out, regardless of its value, if they suspect it involves funds derived from a crime. The same law, however, provides a notable exception: lawyers, other members of the legal profession, and independent accountants are not required to report a transaction if the related information was obtained in circumstances in which they are bound by professional secrecy.
The Prohibition on Tipping Off the Customer
Jordan's law pairs the reporting duty with a prohibition on reporting entities, their managers and their employees disclosing to the customer or to anyone else that they have notified the Unit, protecting the confidentiality of the inquiry and preventing the suspect from being tipped off.
Legal References
- Anti-Money Laundering and Counter-Terrorist Financing Law No. 20 of 2021 (Jordan) — Article 18, and Article 19 (Prohibition on Disclosure)
- Federal Decree-Law No. (10) of 2025 on Countering Money Laundering and Combating Terrorist Financing and the Financing of Proliferation (UAE) — Article (18)
- Law No. (20) of 2019 Promulgating the Anti-Money Laundering and Terrorist Financing Law (Qatar) — Article 21
- Law No. 106 of 2013 on Combating Money Laundering and Terrorist Financing (Kuwait) — Reporting Article and the Professional Secrecy Exception
For questions about your specific situation, you can ask the Tax & Legislation Helper for your country on Helpers, or consult a licensed chartered accountant.