Comprehensive List of Fines and Penalties for Money Laundering and Terror Financing in the UAE

 Penalty of Dh1 Million

Entities will be liable to pay a penalty of Dh1 million in the following cases:

– Dealing with Fake Banks: Engaging in transactions with non-existent banks.
– Fake Bank Accounts: Maintaining or opening bank accounts with false names or numbers.
– Sanctions List Non-Compliance: Failing to take required measures for clients on international or domestic sanctions lists before establishing or continuing commercial relationships.

 Penalty of Dh200,000

Entities will be liable to pay a penalty of Dh200,000 in the following cases:

– High-Risk Management Failures: Not implementing due diligence measures for managing high risks.
– Suspicious Transaction Non-Notification: Failing to notify the financial information unit about suspicious transactions when due diligence cannot be completed.
– Non-Compliance with Information Requests: Not responding to additional information requests from the financial information unit related to suspicious transactions.
– Disclosure of Suspicious Nature: Indirectly or directly disclosing the suspicious nature of business relationships to customers or others.
– High-Risk Country Measures Non-Implementation: Failing to implement measures set by the National Committee regarding clients from high-risk countries.

 Penalty of Dh100,000

Entities will be liable to pay a penalty of Dh100,000 in the following cases:

– Crime Risk Assessment Failures: Not taking required measures to determine crime risks in their field of work.
– New Practices Risk Assessment Failures: Not assessing risks arising from new professional practices.
– Due Diligence Failures: Not performing due diligence before establishing or continuing business relationships or transactions.
– Document Verification Failures: Not verifying documents or data from reliable sources.
– Delayed Suspicious Transaction Reporting: Delaying notification to the financial information unit about suspicious transactions when there are firm grounds for suspicion.
– Politically Exposed Clients Due Diligence Failures: Not performing due diligence for politically exposed clients before establishing commercial relationships.
– Record Keeping Failures: Not maintaining required records and tracking financial transactions.

 Penalty of Dh50,000

Entities will be liable to pay a penalty of Dh50,000 in the following cases:

– Risk Detection Measures Failures: Not taking reasonable measures to detect risks as per the national risk assessment.
– Internal Controls and Policies Failures: Not setting up controls, procedures, and policies to combat crime.
– Low-Risk Management Failures: Not managing low risks with simplified measures.
– Commercial Relationship Understanding Failures: Not understanding the purpose and nature of commercial relationships.
– Client’s Business Understanding Failures: Not understanding the nature of the client’s business, ownership structure, and control.
– Continuous Monitoring Failures: Not continuously monitoring business relationships.
– Compliance Officer Appointment Failures: Not appointing a compliance officer.
– Inappropriate Financial Transactions Maintenance: Not maintaining financial transactions for data analysis and tracking.
– Record Keeping Failures: Not keeping transaction records for five years after business relationship termination.
– Information Provision Failures: Not providing relevant information regarding data analysis, records, and documents upon request.
– Employee Training Failures: Not providing adequate training to employees on combating money laundering and financial terrorism risks.