Can a company be held criminally liable for money laundering in the UAE?

UAE
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Yes. A legal person can be held criminally liable where a money laundering, terrorist financing or proliferation financing offence is committed in its name or for its account by its representatives, directors or agents. Corporate liability applies without prejudice to the personal criminal liability of the individual who actually committed the act.

The financial exposure is substantial. A legal person convicted of one of these core crimes faces a fine of not less than AED 5,000,000 and up to AED 100,000,000, or an amount equal to the value of the criminal property, whichever is greater. Where the conviction relates to terrorist financing or proliferation financing, the court must order the entity’s dissolution and closure of its premises. Managers who knew of the offence and breached their duties can also be imprisoned and fined. This makes board and senior-management oversight of the AML programme a direct legal necessity.

Legal Reference (UAE):

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

Money laundering fines and penalties in the UAE

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Yes. A legal person is criminally liable where any of the crimes in the Decree-Law is intentionally committed in its name or for its account. That liability sits alongside, and does not displace, the personal criminal liability of the individual who committed the act, and it is separate again from the administrative penalties the supervisory authority may impose on the entity.

So a single episode can produce three parallel consequences: prosecution of the individual, prosecution of the company, and an administrative penalty from the regulator. Where the crime is committed in the name or for the account of a legal person, the person responsible for its actual management can also be exposed. The defensive value of a documented compliance programme lies precisely here, because it evidences what the company required, trained and monitored, as against what an individual did outside that framework.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 4, which makes a legal person criminally liable where a crime under the Decree-Law is intentionally committed in its name or for its account, without prejudice to the perpetrator’s personal liability or to administrative penalties.

· Federal Decree-Law No. 10 of 2025, Article 17, which sets out the administrative penalties the supervisory authority may impose on the entity.

For your own circumstances, check your internal AML policy or speak to your compliance officer.

Penalties for AML non-compliance in the UAE