What Are The Updates on Penalties and Jail Time for Money Laundering Offenders?

criminal law


February 24, 2022



| Your comment matters, please click here to rate article!

The United Arab Emirates remains committed to combating anti-money laundering practices in the country and thereby imposing strict penalties on offenders in money laundering cases. The extent of the penalties being imposed generally includes imprisonment and fines equivalent to the misappropriated amount.

Defining Money Laundering:

Article 2 of the Federal Decree-Law Number 20 of 2018 on Combating Money Laundering Crimes, the Financing of Terrorism and the Financing of Unlawful Organizations and its amendments (‘AML Decree law’), defines ‘money laundering’ as an activity comprising of any of the following acts:

Whoever had the knowledge that the funds are derived from a predicate offence and wilfully commits any of the acts set out here below shall be considered as committing Money Laundering:

  • Transferring or moving the proceeds or conducting any transaction in respect thereof with the intent of concealing or disguising their illicit source.

  • Concealing or disguising the true nature, source or location of the proceeds as well as the manner of disposal thereof, their movement, their ownership or the rights related thereto.

  • Acquiring, possessing or using the proceeds upon receiving them.

  • Assisting the perpetrator of the predicate offence to escape punishment.

The AML Decree Law (Article 14) seeks to impose administrative fines on financial institutions, designated non-financial businesses and professions, virtual asset service providers and non-profit organizations in case they violate any provision and impose:

  • An administrative penalty of not less than (AED 50,000) fifty thousand dirhams and not more than (AED 5,000,000) five million dirhams for each violation.

Under Cabinet Decision Number 16/2021 On the Consolidated List of Administrative Violations and Fines Imposed Upon the Violators to Combat Money Laundering and Terrorism Subject to the Control of the Ministry of Justice and Ministry of Economy (‘AML Regulations’), a list of penalties have been prescribed for violations relating to money laundering and terrorism financing.

The administrative fines set out in this list, with twenty-six categories, range from AED 50,000 to AED 1,000,000. The fines imposed under the AML Regulations apply to activities of the business sector and designated non-financial businesses and professionals that fall under the supervision of the Ministry of Economy and the Ministry of Justice.

The Fines Imposed by the AML Regulations Include, Amongst Others:

  • A fine of AED 1 million or more will be imposed for failure to take special measures concerning the customers included in international or local sanction lists before establishing or maintaining a business relationship, or opening or maintaining bank accounts using alias, fictitious or fake names, or numbers, rather than holders’ names, or dealing with unauthorized banks in any way whatsoever.

  • A fine of AED 200,000 or more will be imposed for each of the following offences: not taking enhanced due diligence measures to manage high risks, not notifying the Financial Information Unit (FIU) 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, etc.

It should also be noted that the crime of money laundering is always considered an independent crime, and punishment of the offender under the larger crime/ related crime will not automatically preclude the offender from additional punishment for the money laundering offence, thus paving the way for severe overall punishments and penalties.

UAE’s increasingly strong policies on anti-money laundering and counter-terrorism reflect its unrelenting international commitment to ensure that it will not provide a haven to criminals in violation of the AML practices.

Related Links

Copyright © of this article is retained by the author and/or other copyright owners. We explicitly grant you permission to download a copy, without any alteration, of this article for personal non-commercial research or study, without prior permission or any charge. This article can be utilized on your website or for marketing, however, we grant you permission to host this article on your website and no other rights. This content should not be altered in any way or sold commercially in any format without prior permission of the copyright holder. During reference of this article, full biographic details entailing the name of the author, his designation, the institute and the publishing date of the article shall be provided.


No comments found.

Leave a Comment

Your email address will not be published. Required fields are marked *

Want to know more?
Then talk to us.

Client Testimonials

I owe the success of my case to Dr. Hassan's diligent approach. He remained focused, put me at ease and always went the extra mile. Dr. Hassan tirelessly put my case in the best possible light and I cannot thank him enough. I would highly recommend Dr. Hassan - I am grateful to him from the bottom of my heart.

Raphael Lauria
Manager, FME General Trading

Dr. Hassan Elhais is among the best legal consultants I have ever worked with. He has an amazing ability to reduce complex issues into a simple concept that non-legal people can understand. He consistently develops innovative litigation strategies that help us to achieve our ultimate legal goals.

Zhuo Liu

...the extraordinary effort that has been exerted by the staff, and we specially thank Dr. Hassan Mohsen Alhais. Wishing your continues success & excellence...

H.H. Sheikh Saeed Bin
Mohammed Hashir Al Maktoum

I believe everyone should recognize what a difference Dr. Hassan Elhais work has made to people's lives; and especially to our family's life, because we will remain forever grateful to each and every one of his team.

Luis Pozueco

Dr. Hassan Elhais never fears cases that involve exposure and he always gives me his honest assessment of our chances of success, which is invaluable to me.

Bassam Yamout
Director, JM Metal Trading LCC

He aided us not only in providing legal advice but also in all legal issues that required a long term strategic approach to achieve most favorable and optimum outcomes he provided us with high level of professional service.

Philippe Delbecq

Dr. Hassan Elhais is a responsible, reputable counsel who operates to high levels of service.

British Client

Dr Hassan Elhais is responsive, thorough and creative with his advice, and is a valued advisor and legal consultant.

Asma Mattar
Manager, Italian Style

Regardless of the complexity of the matter I know Dr. Hassan Elhais will consider not only legal strategy but also business practicalities in providing advice and litigation options.

Dr. Massimo Hakim
Chairman, Italian Style

I recommend Dr. Hassan Elhais to anyone who says 'I'm in legal trouble'. I was extremely satisfied with the high standard of his work. He has always been there when I have needed him and I refer all my clients, family and friends to him/his firm.

Manish Gupta
Marketing Manager, Express Digital System

Dr. Hassan Elhais was very professional and he listened to my needs. He was very prompt, efficient and always kept me informed. Dr. Hassan Elhais's service was excellent and I would definitely recommend him to friends and colleagues.

James Horsley
British Client

Select your Language:


Main Menu