What is the penalty for not reporting a suspicious transaction in the UAE?

UAE
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Failing to report a suspicious transaction is a criminal offence, not merely an administrative one. Any person who, deliberately or through gross negligence, breaches the reporting obligation faces imprisonment and a fine of not less than AED 100,000 and not more than AED 1,000,000, or one of these two penalties.

This applies to financial institutions, DNFBPs, and VASPs and can attach to responsible individuals. Separately, the supervisory authority can impose administrative penalties for the same failure, ranging from a warning to fines and, in serious cases, licence restrictions. The reporting duty arises whenever suspicion is formed, regardless of transaction value, so a low-value deal is not exempt.

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.

Related guidance on amluae.com

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Whoever deliberately or through gross negligence violates the reporting obligation is punished by imprisonment and a fine of not less than AED 100,000 and not more than AED 1,000,000, or by either of those penalties.

Note the fault standard. The offence is not limited to deliberate concealment: gross negligence is enough, which puts weight on whether your monitoring and escalation arrangements were adequate rather than only on what an individual chose to do. Where a legal person commits the offence through its representatives, directors or agents, the fine runs from AED 200,000 to AED 10,000,000, and the person responsible for actual management can be personally punished if aware of the offence and in breach of their duties.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 28: imprisonment and a fine of AED 100,000 to AED 1,000,000 for deliberate or grossly negligent breach of Article 18.

· Federal Decree-Law No. 10 of 2025, Article 27(2) and (5): the legal person fine and the personal liability of the person responsible for actual management.

For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.

Suspicious transaction reporting