Can an attempt to commit money laundering be punished in the UAE?
Yes. Under the UAE AML law, an attempt to commit money laundering, terrorist financing or proliferation financing is punishable with the same penalty prescribed for the completed crime. The law does not treat a failed or interrupted attempt as a lesser matter, which closes a common loophole where offenders argue that no laundering was ultimately achieved.
This matters because money laundering is also treated as an independent crime. A conviction for the underlying predicate offence is not required, and the illegitimate source of the proceeds can be established without proving the specific type of predicate crime. Knowledge that funds were criminal proceeds may be inferred from the objective circumstances of the case.
For businesses, the practical takeaway is that the law captures conduct at an early stage. Assisting with, or taking steps towards, the movement or concealment of suspected criminal proceeds can attract full liability even if the scheme does not succeed. Robust customer due diligence, transaction monitoring and prompt suspicious transaction reporting are the main defences against becoming caught up in such conduct.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 26(5) — an attempt is punishable with the same penalty as the completed crime.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.