What penalties apply if a UAE entity fails to conduct an adequate AML risk assessment?
A UAE regulated entity that fails to conduct, document or update an adequate risk assessment can face administrative penalties from its Supervisory Authority. The law allows a range of sanctions, from a warning up to administrative fines of not less than AED 10,000 and not exceeding AED 5,000,000 for each violation, with the possibility of higher, incremental fines where the same breach recurs within a year.
More serious or persistent failures can lead to restrictions on activity, suspension or replacement of responsible managers, appointment of a temporary supervisor, or revocation of the licence. Penalties may also be published. Enforcement is active: supervisors regularly fine firms for weak risk assessments and related AML failings, so a documented, current risk assessment is a core defence.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 17(1) — administrative penalties, including fines of AED 10,000 to AED 5,000,000 per violation.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(a) — the underlying obligation to assess, document and update risks.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.