Latest UAE Fines for Money Laundering, Terror Financing

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The UAE’s Ministry of Economy has announced the list of violations and fines for money laundering and terrorism financing. The ministry has issued a list of 26 penalties. The violations pertain to the designated non-financial businesses and professions (DNFBPs) that the ministry supervises. The businesses include four main categories: Brokers and real estate agents; dealers of precious metals and gemstones; auditors; and corporate service providers.

Dh 1 million fine

Failure to take enhanced due diligence measures to manage high risks.
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 the additional information request by the Financial Information Unit regarding the suspicious transaction report that has been filed.
Disclosure, directly or indirectly, to the customer or to others about reporting the customer or the intention to report him, on suspicion of the nature of the business relationship with him.
Failure to implement the measures set by the National Committee to Combat Money Laundering with regard to clients from high-risk countries.

Dh 200,000 fine

Dealing with fake banks.
Opening or maintaining bank accounts with fake names or numbers without the names of their owners.
Failure to take measures related to clients listed on international or domestic sanctions lists, prior to establishing or continuing a business relationship.

Dh 100,000 fine

Failure to take the necessary measures to determine the risks of crime in one’s field of work.
Failure to identify and assess risks that may arise in his field of work when he develops the services he provides or undertakes new professional practices through his establishment.
Failure to take due diligence measures towards clients before establishing or continuing a business relationship or carrying out a process in the name of or for the benefit of the client.
Failure to verify – using documents or data from a reliable and independent source – the identity of the customer and the real beneficiary before establishing a business relationship.
Delay in informing the Financial Information Unit of a suspicious transaction report if there are reasonable grounds to suspect that the business relationship with the customer is linked to the crime in whole or in part; or that the client’s money is from the proceeds of a crime or used in it.
Failure to apply due diligence measures towards politically exposed clients before establishing or continuing a business relationship.
Not creating records to keep track of financial transactions with clients.

Dh 50,000 fine

Failure to take necessary measures and procedures to reduce the identified risks according to the results of the national risk assessment.
Failure to set internal policies, procedures, and controls at the facilities aimed at combating the crime or engaging in a suspicious business relationship.
Failure to take simplified due diligence measures to manage low risk.
Failure to take the necessary measures to understand the purpose and nature of the business relationship.
Failure to take the necessary measures to understand the nature of the client’s business, the ownership structure of his business, and the extent of the client’s control over it.
Failure to take due diligence measures of continuous monitoring towards clients during the business relationship.
Failure to appoint a compliance officer.
Create records for keeping financial transactions with clients in an irregular manner that does not allow data analysis and tracking of financial operations.
Failure to keep records of financial transactions and documents related to them for a period of five years from the date of completion of the process or the termination of the business relationship with the customer or from the date of the end of the inspection process of his facility.
Failure to provide information related to customer due diligence and continuous monitoring and results of their analysis, as well as their records, files, documents, correspondence, and forms to the authorities concerned upon request.
Failure to train employees at a facility on countering money laundering and combating terrorism financing.

Failure to take necessary measures and procedures to reduce the identified risks according to the results of the national risk assessment.
Failure to set internal policies, procedures, and controls at the facilities aimed at combating the crime or engaging in a suspicious business relationship.
Failure to take simplified due diligence measures to manage low risk.
Failure to take the necessary measures to understand the purpose and nature of the business relationship.
Failure to take the necessary measures to understand the nature of the client’s business, the ownership structure of his business, and the extent of the client’s control over it.
Failure to take due diligence measures of continuous monitoring towards clients during the business relationship.
Failure to appoint a compliance officer.
Create records for keeping financial transactions with clients in an irregular manner that does not allow data analysis and tracking of financial operations.
Failure to keep records of financial transactions and documents related to them for a period of five years from the date of completion of the process or the termination of the business relationship with the customer or from the date of the end of the inspection process of his facility.
Failure to provide information related to customer due diligence and continuous monitoring and results of their analysis, as well as their records, files, documents, correspondence, and forms to the authorities concerned upon request.
Failure to train employees at a facility on countering money laundering and combating terrorism financing.

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Source: Khaleej Times