The UAE AML Law places clear responsibility on senior management, and supervisory authorities have express powers to sanction responsible individuals, not just the entity. Internal policies, controls and procedures must be approved by senior management, which anchors accountability for the compliance framework at the top of the organisation.
Where a violation occurs, the supervisory authority may restrict the powers of the board members, executive, supervisory or managerial personnel, or owners proven responsible for the violation, including appointing a temporary supervisor. It may also suspend directors, board members or executives responsible for the violation, or require their replacement. These measures make individual accountability tangible. In effect, the law adopts a top-down model in which boards and senior management are expected to set the tone, ensure adequate resources for compliance, approve and review policies, and oversee risk. Directors and officers should therefore ensure the firm has a documented risk assessment, an empowered compliance function, and management information that lets them demonstrate active oversight if challenged.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 19(1)(d) - requires internal policies to be approved by senior management.
- Federal Decree-Law No. 10 of 2025, Article 17(1) - allows penalties against responsible board members, executives and owners.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.