Can managers be held personally liable under the UAE AML law?
Yes. Federal Decree-Law No. 10 of 2025 provides that where an offence is committed in the name or for the account of a legal person, the person responsible for its actual management can be punished by imprisonment and a fine, or either penalty, if it is proven that they were aware of the offence and that its commission resulted from a breach of the duties of their position.
This personal criminal liability sits alongside, and does not replace, the fine imposed on the legal person itself. It significantly raises the stakes for board members, senior executives and managers, who can no longer treat AML failures as purely corporate risk. In practice, this makes active oversight, adequate resourcing of the compliance function, and documented decision-making essential defensive measures for senior management.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 27(5) — establishes personal liability of the person managing a legal person
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.