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The UAE Ministry of Economy has announced the list of penalties
for violations of the laws relating to money laundering and
terrorism financing. Around twenty-six categories of fines have
been listed, ranging from AED 50,000 to AED 1,000,000.
In addition to step up the monitoring of money laundering
activities in the UAE, the ministry has established a specialized
administrative unit .The said unit is authorized for the inspection
and control of designated non-financial businesses and professions
such as real estate agents and brokers, dealers of precious metals
and gemstones, auditors, corporate service providers etc.
List of Fines:
Type of Violation
Fine of Dirhams 1 million or more
- Failure to take the special measures concerning the customers
included in international or local sanction lists before
establishing or maintaining business relationship.
- Opening or maintaining bank accounts using alias, fictious or
fake names, or numbers, rather than holders' names.
- Dealing with unauthorized banks in any way whatsoever.
Fine of Dirhams 200,000 or more
- Not taking enhanced due diligence measures to manage high
- Not notifying the Financial Information Unit of a suspicious
transaction report when it is not possible to take due diligence
measures towards a client before establishing or continuing a
business relationship with him or carrying out a transaction for
the benefit of the client or in his name.
- Failure to respond to FIU's requests for additional
information regarding any reported suspicious transactions.
- Disclosing, directly or indirectly, to the customer or a third
party, the process of, or intention to, report the customer due to
suspicions about the nature of business relationship with the
- Failure to implement the measures identified by the National
Committee for Combating Money Laundering in respect of customers
from high-risk countries.
Fine of Dirhams 100,000 or more
- Not taking necessary measures to determine crime risks in his
field of work
- Failure to identify and evaluate risks that may arise in his
field of work when he develops the services he provides or
undertakes new professional practices through his
- Not taking due diligence measures towards clients before
establishing or continuing a business relationship or executing a
transaction in the name of or for the benefit of the customer
- Not verifying - using documents or data from a reliable and
independent source - the identity of the customer and the real
beneficiary or their deputy before or during the establishment of
the business relationship or the opening of the account, or before
carrying out a process for a client with whom he has no existing
- Delay in informing the Financial Information Unit of a
suspicious transaction report in the event of suspicion or the
availability of reasonable grounds to suspect that the business
relationship with the customer is related to the crime in whole or
in part, or that the client's money subject to the business
relationship is from the proceeds of crime or used in it.
- Failure to implement due diligence measures towards politically
exposed customers prior to establishing or maintain business
- Failure to create records on financial transactions with the
Fine of Dirhams 50,000 or more
- Failure to train staff on combating money laundering and
- Failure to ensure competent authorities' access, upon their
request, to the information related to customers' due diligence
and continued monitoring, as well as the findings of analyzing the
same, and the records, files, documents, correspondence, and forms
pertaining to both sides.
- Failure to keep records of the financial transactions and
relevant documents for five years from the date of transaction
completion, or the expiry of the business relationship with the
customer, or the completion of inspection of their facility.
- Create records to save the financial transactions with the
customers in an irregular manner that does not enable data analysis
and financial transaction tracking
- Failure to appoint a compliance officer
- Not taking due diligence measures for continuous monitoring,
towards clients during the business relationship
- Not taking necessary procedures to understand the nature of the
client's business, the ownership structure of his work, and the
extent of the client's control over it.
- Not taking necessary measures to understand the purpose and
nature of the business relationship, or he did not seek to obtain
information related to this purpose when needed.
- Not taking simplified due diligence measures to manage low
- Not setting internal policies, procedures and controls at his
facility to combat the crime or engaging in a suspicious business
- Not taking the necessary measures and procedures to reduce the
identified risks according to the results of the national risk
assessment, or the results of the self-assessment, given the nature
and volume of his work.
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guide to the subject matter. Specialist advice should be sought
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