AML Fines and Penalties in the UAE: What the Law Actually Says
Rajesh KumarRegulatory landscape 8 min read Published 2 November 2026
The UAE's current AML law, Federal Decree-Law No. 10 of 2025, sets out two tracks of penalties: administrative penalties imposed by supervisory authorities for compliance failures, and criminal penalties for money laundering, terrorist financing and proliferation financing offences. Administrative fines range from AED 10,000 to AED 5,000,000 per violation. Criminal penalties for money laundering carry one to ten years' imprisonment and fines of AED 100,000 to AED 5,000,000. Corporate fines can reach AED 100,000,000. Both tracks can apply simultaneously.
Key takeaways
- Administrative fines for compliance failures range from AED 10,000 to AED 5,000,000 per violation under Article 17.
- Money laundering carries one to ten years' imprisonment and a fine of AED 100,000 to AED 5,000,000, or the value of the criminal property if greater.
- Terrorist financing penalties include life imprisonment or at least ten years, with fines of AED 1,000,000 to AED 10,000,000.
- A legal person (company) convicted of a money laundering offence faces fines of AED 5,000,000 to AED 100,000,000.
- Administrative and criminal sanctions can run in parallel for the same conduct.
Why the numbers online are often wrong
Search for 'AML fines UAE' and you will find a range of conflicting figures. Some sites still quote the penalty ranges from the 2018 law, which was replaced in 2025. Others cite headline numbers without distinguishing between administrative and criminal penalties, or between individual and corporate liability. A few invent figures entirely.
This article sets out the penalty framework from Federal Decree-Law No. 10 of 2025, which is the current law. Every figure below is drawn from the published text. If anything changes, we will update this page.
Administrative penalties
Administrative penalties are imposed by the relevant Supervisory Authority, which is the body that licenses or supervises your business. For banks and exchange houses, that is the Central Bank. For securities firms, the SCA. For DNFBPs such as real estate agents, accountants, lawyers and dealers in precious metals and stones, it is typically the Ministry of Economy and Tourism. The DFSA and ADGM have their own enforcement powers within their free zones.
Under Chapter Seven of the law, the Supervisory Authority may impose the following for non-compliance with AML, CFT or CPF obligations:
| Measure | Detail |
|---|---|
| Written warning | A formal notice of the breach |
| Administrative fine | AED 10,000 to AED 5,000,000 per violation |
| Sector ban | Prohibiting a person from working in the regulated sector for a period set by the authority |
| Licence restriction, suspension or revocation | Limiting, suspending or withdrawing the entity's authorisation to operate |
These are not criminal penalties. They do not require a criminal conviction. The Supervisory Authority can impose them on the basis of an inspection finding or a failure to meet a regulatory requirement. Common triggers include:
- Failure to register on goAML or to appoint a compliance officer
- An inadequate or outdated institutional risk assessment
- Weak or absent customer due diligence procedures
- Failure to file suspicious transaction reports when there were grounds to suspect
- Incomplete or inaccurate beneficial ownership records
- Failure to maintain records for the required retention period
- Not providing staff with adequate AML training
Criminal penalties: individuals
Criminal penalties apply to the substantive offences of money laundering, terrorist financing and proliferation financing. These are prosecuted through the courts, not by supervisory authorities.
| Offence | Imprisonment | Fine |
|---|---|---|
| Money laundering | 1 to 10 years | AED 100,000 to AED 5,000,000, or the value of the criminal property if greater |
| Terrorist financing | Life imprisonment or at least 10 years | AED 1,000,000 to AED 10,000,000, or twice the value of the property if greater |
| Proliferation financing | As specified in the law, aligned with UN Security Council resolutions | As specified in the law |
Ancillary offences also carry penalties. Tipping off a person that they are the subject of a suspicious report, failing to comply with a freezing order, or obstructing an investigation can each result in imprisonment and fines.
Criminal penalties: companies
A legal person, meaning a company, whose representatives commit a money laundering or terrorist financing offence in its name or on its behalf, faces a fine of AED 5,000,000 to AED 100,000,000, or an amount equivalent to the value of the criminal property involved, whichever is greater.
The corporate penalty does not shield the individuals involved. Directors, officers and compliance staff who were responsible for or complicit in the offence face the individual penalties as well. This is why senior management buy-in matters: a compliance failure is not just the compliance officer's problem.
The law also provides for the dissolution or temporary closure of the legal person, confiscation of assets used in or derived from the offence, and publication of the judgment. These additional measures can be more damaging to a business than the fine itself, particularly where reputational harm affects client relationships, banking access or licence renewals.
Both tracks can apply at once
Administrative and criminal proceedings are separate. A business can receive an administrative fine from its Supervisory Authority for a compliance failure and face a criminal prosecution for the underlying offence at the same time. The administrative penalty does not replace or reduce the criminal one, and vice versa.
How enforcement is increasing
The UAE has been steadily increasing enforcement activity since its removal from the FATF grey list in February 2024. Supervisory authorities across all sectors are conducting more inspections and imposing penalties more readily. The upcoming FATF 5th round mutual evaluation in 2026 has further intensified this trend, as authorities need to demonstrate effective enforcement to the assessment team.
This is not limited to financial institutions. DNFBPs, including real estate agents, precious metals dealers, accountants, lawyers, company service providers and virtual asset service providers, are all subject to inspection and enforcement. The Central Bank, SCA, DFSA, ADGM and Ministry of Economy and Tourism have all increased their inspection programmes and published enforcement actions in recent years.
Businesses that have not been inspected before should not assume they are below the radar. Supervisory authorities are expanding their coverage to include smaller entities and sectors that were previously subject to less scrutiny. A first inspection that uncovers significant weaknesses can result in immediate administrative penalties, particularly if the failings are fundamental, such as the absence of a risk assessment, no goAML registration or no appointed compliance officer.
How to reduce your exposure
The law does not prescribe a formula for how penalties are calculated within the ranges. The Supervisory Authority considers factors including the severity of the breach, whether it was a first offence, the degree of cooperation and the steps the business has taken to remedy the failure. That means the following practical steps genuinely reduce exposure:
- Keep your institutional risk assessment current and specific to your business. A generic template will not protect you.
- Make sure your compliance programme is operational, not just documented. Inspectors look at evidence: screening logs, training attendance, escalation records, board minutes.
- File suspicious reports when you have grounds to suspect. A business with zero STRs over an extended period raises a red flag in itself.
- Fix findings promptly when an inspection identifies weaknesses. Demonstrating remediation before a penalty is imposed can make a material difference.
- Cooperate with the Supervisory Authority. Obstruction or delay makes everything worse.
- If you are unsure where you stand, commission an independent AML review before the regulator arrives.
Official sources
The penalty figures in this article are drawn from the following official source. Verify against the current published text before relying on them.
Where Adventant fits
Adventant helps businesses across the UAE strengthen their AML compliance programmes and prepare for regulatory inspections. Whether you need to remediate findings from a recent inspection, commission an independent review before the regulator arrives, or build a compliance programme from the ground up, our team has the experience to guide you through the process. We work with banks, exchange houses, insurance companies, real estate firms, professional services and virtual asset service providers across the UAE mainland and financial free zones. If you want to understand where you stand before the regulator asks, speak to our team.
Frequently asked questions
What is the maximum AML fine for a company in the UAE?
A legal person convicted of a money laundering offence faces a criminal fine of AED 5,000,000 to AED 100,000,000, or the value of the criminal property if greater, under Federal Decree-Law No. 10 of 2025.
Can a business receive both an administrative fine and a criminal penalty?
Yes. Administrative penalties from the Supervisory Authority and criminal prosecution through the courts are separate tracks and can apply to the same conduct simultaneously.
What triggers an administrative AML fine in the UAE?
Common triggers include failure to register on goAML, an inadequate risk assessment, weak customer due diligence, failure to file suspicious transaction reports, incomplete beneficial ownership records and insufficient staff training.
Which law sets out AML penalties in the UAE?
Federal Decree-Law No. 10 of 2025 is the current law. It replaced the 2018 AML law and covers money laundering, terrorist financing and proliferation financing offences, as well as administrative penalties for compliance failures.