A request for transaction records can raise difficult questions for a business. Is the company being inspected, has a customer attracted suspicion, or does an allegation concern a director personally? For anyone searching for “criminal lawyer Dubai”, the first priority is identifying that distinction. The response should reflect the actual request, the relevant authority and the person whose interests require protection.
This guide explains the federal framework and practical response priorities for UAE financial crime investigations as at 5 November 2026. An allegation needs careful examination against the evidence and the requirements of the specific offence.
Establish which process has begun
Regulatory supervision, financial intelligence analysis and criminal investigation serve different purposes. A regulator examines compliance within its remit. The Financial Intelligence Unit receives and analyses suspicious transaction information and disseminates relevant results to law enforcement. The Public Prosecution conducts criminal investigations and prosecutions. Information can pass between these processes, but a regulatory request does not itself establish criminal guilt.
The Central Bank of the UAE’s 2025 Annual Report records AED 200.5 million in fines for AML/CFT breaches in its enforcement tables. This describes regulatory enforcement, not the value of criminal proceeds or fines imposed by criminal courts under the 2025 AML law. A particular company or director’s criminal exposure requires its own assessment of the statutory conditions and evidence.
Record who issued the request, its reference number, what it requires and any stated response date. Confirm whether an individual is being contacted as a witness, an authorised company representative or an accused person. That status may change as facts develop. Avoid choosing a response strategy solely from the informal description given by a customer or colleague.
Assign a responsible contact to coordinate the company response, while preserving access to independent advice for affected individuals. Keep a separate list of operational issues, such as payroll, supplier commitments and access to accounting systems, so the legal team can understand the practical effect of each request or restriction.
Use the current legislation
Federal Decree Law No 10 of 2025 replaced Federal Decree Law No 20 of 2018. Its executive regulations are Cabinet Resolution No 134 of 2025, effective from 14 December 2025. Older compliance manuals should therefore be checked against the current framework.
Article 2 of the 2025 law requires one of the specified intentional acts involving criminal proceeds and knowledge that the funds derive wholly or partly from a predicate offence. That knowledge may be established through sufficient indications or evidence and inferred from factual and objective circumstances. A conviction for the predicate offence is unnecessary. An unexplained payment warrants examination, but does not automatically establish money laundering.
Article 39 of Federal Decree Law No 31 of 2021 distinguishes intent from fault, including negligence. The requirements of the particular offence remain essential. A poor approval process and participation in a deliberate deception are different factual issues that must be analysed separately.
Separate company exposure from personal exposure
Article 66 of the Crimes and Penalties Law addresses offences committed by representatives, directors or agents for a legal person's benefit or on its behalf, subject to the stated public entity exceptions. Corporate liability does not remove the perpetrator's personal liability. Article 4 of the 2025 AML law separately addresses crimes intentionally committed in a legal person's name or for its account.
The AML law also contains a specific management provision. Under Article 27 paragraph 5, liability of the person responsible for actual management requires proof of awareness of the relevant crime and that its commission resulted from a breach of that person's duties. Holding a director title alone does not establish those conditions.
Article 27 provides substantial corporate penalties, including a fine of AED 5 million to AED 100 million, or the value of the criminal property if greater, for the specified laundering and financing crimes. These special provisions must be considered instead of assuming that the general corporate fine provision supplies the applicable ceiling.
Map each person's actual responsibilities, approval authority, information received and actions taken. The company and its directors may need separate advisers where their accounts or interests differ. Agree who counsel represents before sharing personal explanations through a company response team.
Preserve the evidence before reconstructing events
Give clear instructions to preserve relevant accounting records, correspondence, messages, approval logs and supporting documents. Suspend routine deletion affecting those records. Include material held by departing staff, outsourced accountants and service providers, where the company can lawfully obtain it. Preservation should retain original content and context, including dates and available metadata.
Create a chronology that distinguishes verified facts from unresolved questions. For each disputed payment, identify the commercial purpose, recipient, approval, supporting invoice and evidence of delivery. Record gaps openly. An internal review should never involve backdating an approval, replacing an invoice, coaching witnesses or moving records out of reach.
For businesses within its scope, Article 25 of Cabinet Resolution No 134 of 2025 requires organised records capable of reconstructing transactions and prompt availability to authorities. Relevant retention periods are at least five years, with different starting points and, for certain records, reference to the latest specified event. A simple rule of deleting everything five years after payment can therefore be wrong.
Prepare for questions and document requests
Before an interview, review the available records with counsel and distinguish personal recollection from assumptions. Explain technical accounting terms accurately. If a question or recorded answer is unclear, ask for clarification or correction. Raising interpretation needs early helps avoid an inaccurate account.
Under Article 97 of Federal Decree Law No 38 of 2022, the prosecutor informs the accused of the charge and records the answers. Article 98 permits the accused's attorney to attend and review investigation papers, subject to a prosecutor's contrary decision in the investigation's interests. Access should therefore be requested without promising unrestricted attendance or disclosure.
Articles 72 and 73 provide for searches, seizure and examination of electronic systems. Article 76 addresses orders to produce items. Article 75 protects specified documents delivered to defence counsel and case correspondence, but should not be treated as blanket protection for every business record or internal report.
Article 67 also treats investigation procedures and results as confidential, with duties for those participating through their official role.
Maintain a record of documents provided, the request addressed and the person responsible for the response. Counsel should assess confidentiality questions promptly while ensuring lawful demands are addressed. Do not conceal material simply because it is commercially sensitive.
Manage reporting and communications carefully
Article 18 requires financial institutions, designated nonfinancial businesses and professions, and virtual asset service providers to report relevant suspicions directly to the FIU without delay. This obligation arises on the statutory suspicion threshold, rather than requiring the reporting entity to prove a crime. Its professional secrecy exception concerns specified professionals and circumstances.
Identify whether the business and activity fall within those obligations. An internal investigation should not become a reason to postpone a required report. Coordinate reporting through the responsible compliance personnel, with legal advice on the applicable duties.
Article 29 penalises prohibited warnings and disclosure concerning suspicious transactions or related inquiries. It also addresses intentional or grossly negligent breaches concerning entrusted funds and precautionary orders. Restrict information to appropriate recipients and assess proposed explanations to customers, suppliers or staff before communicating them.
An asset restriction requires its own response. Article 6 allows relevant prosecution and court measures without advance notice and provides a grievance mechanism for specified decisions. Review the actual order before considering a challenge. Never transfer assets to evade it.
Frequently Asked Questions
1. Is every director liable when a company is investigated?
No. Investigation and liability are different matters. Personal responsibility depends on the offence, evidence and applicable legal conditions. For the specific actual management provision in Article 27 paragraph 5, awareness and a breach of duties causing the crime must be established.
2. Should a business wait for proof before reporting suspicion?
A business subject to Article 18 must report when the statutory suspicion conditions are met. Waiting for a completed internal inquiry or a conviction can misunderstand that duty. Counsel and compliance staff should identify the applicable reporting obligations promptly.
3. What should be ready for an initial legal consultation?
Bring the request or complaint, company structure, relevant transactions, approval records and a factual chronology. Identify imminent interviews, response dates and asset restrictions. When comparing “criminal lawyer Dubai” search results, focus on relevant experience, who will handle the matter and whether separate representation is needed.
4. What should a business record when documents are requested?
Keep the issuing authority, request reference, deadline and scope together. Record the documents supplied, the submission date and the responsible person. Identify missing material and requests for clarification while preserving the originals and the full factual context.
5. How should a company prepare a transaction chronology?
For each relevant payment, identify its date, parties, stated purpose, approval and supporting records. Separate verified facts from recollection and unanswered questions. Include conflicting evidence and explain gaps openly so counsel can assess the request and the individual roles involved.
About the author
Dr. Hassan Elhais is a Senior Legal Consultant at Amal Al Rashedi Lawyers and Legal Consultants in Dubai. He advises on UAE family, civil, commercial and criminal law matters.
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About the Author
Dr. Hassan Elhais publishes analysis of UAE criminal law matters, including criminal investigations, procedural questions and criminal-law disputes. For readers researching a criminal lawyer in Dubai, his writing offers insight into the legal questions surrounding these topics. Explore his published work and practice-area information for further context.
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