What penalties can a company or legal person face for money laundering in the UAE?
A legal person can be held criminally liable where its representatives, directors or agents commit money laundering, terrorist financing or proliferation financing on its behalf or in its name. Under the new UAE AML law, the company faces a fine of not less than AED 5 million and not exceeding AED 100 million, or an amount equal to the value of the criminal property involved, whichever is greater. This is a substantial increase on the ceiling under the previous law.
The consequences can go beyond a fine. Where a legal person is convicted of terrorist financing or proliferation financing, the court must order its dissolution and the closure of the premises where its activity is conducted. For a money laundering conviction, the court has discretion to order the same. In addition, the person actually managing the company can be personally imprisoned and fined if it is proven they were aware of the crime and that it resulted from a breach of their duties.
Boards and senior management should treat AML controls as a direct corporate liability issue, not merely a regulatory formality.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 27 — sets fines of AED 5 million to AED 100 million for legal persons and allows dissolution.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.