What penalties can a UAE law firm face for AML non-compliance?
A UAE law firm that breaches its AML obligations can face administrative penalties imposed by its supervisory authority. These range from a written warning to fines of not less than AED 10,000 and up to AED 5,000,000 for each violation, as well as restrictions on the activity, suspension or replacement of responsible managers, and in serious cases suspension of the profession or revocation of the licence. Fines can be increased for repeat violations within a year.
Separately, the underlying money laundering offence carries criminal penalties. A person convicted of money laundering faces imprisonment and a fine of not less than AED 100,000 and up to AED 5,000,000, with heavier penalties where the offender exploited their professional position. For a professional gatekeeper such as a lawyer, the reputational damage of an enforcement action often outweighs the fine itself, which is why a documented, working AML programme is the best protection.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 17 - sets administrative penalties from AED 10,000 to AED 5,000,000 per violation.
· Federal Decree-Law No. 10 of 2025, Article 26 - sets criminal penalties for money laundering.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.