Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

16cases from 1 jurisdiction
€53mTotal of monetary amounts (9 cases with an amount)
€48.4mLargest single case: Wechselstube (anonymisiert)
€479,179Median per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Central Bank of the UAE (CBUAE) €52.4m 99 % · 6 cases
  2. Financial Services Regulatory Authority (ADGM) €583,951 1 % · 6 cases
  3. Virtual Assets Regulatory Authority (VARA), Dubai – 0 % · 4 cases

What for?

by topic
  1. Internal controls €52.5m 99 % · 11 cases
  2. Customer due diligence €535,738 1 % · 5 cases

Who?

by sector

All sectors

  1. Financial services and insurance €52.9m 100 % · 12 cases
  2. Other €74,061 0 % · 4 cases

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q4 20230–
Q1 20240–
Q2 20240–
Q3 20240–
Q4 20241€479,179
Q1 20252€913,388
Q2 20253€50.8m
Q3 20255€715,155
Q4 20252€74,890
Q1 20260–
Q2 20262–
Q3 20261–
Q4 20260–

16 cases

20 May 2025 Wechselstube (anonymisiert)CBUAE fines exchange house AED 200m over serious AML failings United Arab EmiratesInternal controls €48.4m

The Central Bank of the UAE (CBUAE) fined an unnamed exchange house AED 200 million under Article 137 of the central bank law (Decretal Federal Law No. 14 of 2018). CBUAE examinations had found significant failures in the company's framework for combating money laundering and the financing of terrorism and illegal organisations.

What organisations can take from it

Weaknesses in an anti-money laundering framework can trigger very large fines.

Relevance to training and awareness

AML frameworks at exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018 Regarding the Central Bank and Organization of Financial Institutions and Activities
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
20 May 2025

Original amount 200,000,000 AED, converted at the ECB reference rate of 20 May 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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24 Jul 2026 Shelbit General Trading L.L.CVARA sanctions Shelbit again for unlicensed crypto services, missing KYC and promotion United Arab EmiratesCustomer due diligence Fine

Despite a cease-and-desist notice and enforcement action of 2 January 2025, the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator) found that Shelbit General Trading L.L.C (Shelbit Exchange) continued to provide virtual asset services in and from Dubai without a licence, onboarded users without the mandatory KYC checks and promoted its services without authorisation. VARA again imposed fines of an undisclosed amount and ordered it to cease immediately; according to the regulator, the risk identified also concerned cross-border transactions with possible consequences for the integrity of the UAE financial system.

What organisations can take from it

Disregarding a cease-and-desist order leads to further sanctions – the regulator keeps monitoring the market after the first action.

Relevance to training and awareness

Compliance with cease-and-desist orders and KYC obligations

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Federal Decree-Law No. (10) of 2025 (AML/CFT/PF); Cabinet Resolution No. (111) of 2022; Dubai Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; VARA Regulations and Rulebooks
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Published
24 Jul 2026

Checked against the official source on 3 Oct 2026 · Direct link

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17 Jun 2026 MX Global Ltd (MEXC)VARA fines MX Global (MEXC) for unlicensed crypto services and missing KYC United Arab EmiratesCustomer due diligence Fine

According to investigations by the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator), MX Global Ltd, which trades under the MEXC brand, provided broker-dealer and/or exchange services to customers in Dubai without a licence from 2022 to April 2026 and onboarded users without the KYC checks required by law. VARA imposed fines of an undisclosed amount and ordered the immediate cessation of all unlicensed activities in or from Dubai; other group companies were expressly not affected.

What organisations can take from it

Serving customers in a market requires a licence there – and local KYC obligations must be met regardless.

Relevance to training and awareness

Licensing requirement and KYC for cross-border crypto services

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Federal Decree-Law No. (10) of 2025 (AML/CFT/PF); Dubai Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Cabinet Resolution No. 111/2022; VARA Regulations and Rulebooks
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation, compliance with the cease-and-desist orders and a stated intention to apply for a VARA licence.
Published
22 Jun 2026

Checked against the official source on 3 Oct 2026 · Direct link

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3 Jun 2026 CoinMENA FZEVARA fines CoinMENA over failings in its anti-money laundering programme United Arab EmiratesInternal controls Fine

The Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator) had licensed CoinMENA FZE to provide broker-dealer services on 30 November 2023. In ongoing supervisory inspections covering its entire market operations from the outset up to and including the 2025 financial year, VARA found administrative weaknesses in internal systems and controls that led to compliance failures in the company's anti-money laundering programme. VARA imposed a fine, the amount of which was not published.

What organisations can take from it

Even a licensed provider must keep its anti-money laundering programme aligned with its actual operations – the regulator reviews the entire period of operation.

Relevance to training and awareness

Internal controls in the AML programmes of crypto service providers

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Internal controls
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation, acceptance of the findings and a coordinated remediation plan.
Published
22 Jun 2026

Checked against the official source on 3 Oct 2026 · Direct link

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17 Dec 2025 Payward MENA Holdings LimitedADGM: allegedly 36,000 USD fine for Payward MENA Holdings over five years of late AML returns United Arab EmiratesInternal controls €30,711

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the operator of a multilateral trading facility, which also held a custody permission, allegedly 36,000 USD because it did not file its annual AML returns for 2020 to 2024 until 16 December 2025 despite numerous reminders and did not pay the late filing fees of 2,000 USD in total. The regulator also found inadequate systems and controls; in correspondence the firm pointed to internal issues and to the departure of the user registered for the reporting portal. Without the 20% discount for early settlement the fine would have been 45,000 USD.

What organisations can take from it

Regulatory returns need clear ownership and portal access that survives staff changes.

Relevance to training and awareness

Timely regulatory returns to the supervisor

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 232 Financial Services and Markets Regulations 2015 (FSMR); AML Rule 4.6.1; GEN Rule 2.2.3 (Principle 3); FEES Rule 1.2.7
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Full cooperation, remediation, no previous non-compliance, limited scale of business with few clients and no customer loss identified (10% reduction); 20% discount for early settlement.

Original amount 36,000 USD, converted at the ECB reference rate of 17 Dec 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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24 Nov 2025 FWS Group LtdADGM: allegedly 51,000 USD fine for business centre operator FWS Group over missing customer checks United Arab EmiratesCustomer due diligence €44,179

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the operator of a business centre, registered as a company service provider, allegedly 51,000 USD for anti-money laundering failings between December 2022 and December 2023. The firm had not carried out a business risk assessment and could not show a risk assessment for any of its 104 customers (tenants), nor had it verified any of them, because its outsourced compliance provider treated only the external operator of the centre as a customer; in addition, after the money laundering reporting officer (MLRO) had been absent for a long period, a replacement was only appointed after about ten months and the regulator was not promptly informed. Without the 20% discount for early settlement the fine would have been 63,750 USD.

What organisations can take from it

A firm that outsources operations and compliance remains itself responsible for due diligence on all of its own customers.

Relevance to training and awareness

Who the customer is: due diligence duties when operations and compliance are outsourced

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 6.1.1, 7.1.1(1)(a) und (b), 7.1.2(1)(a), 8.3.1(1)(d), 8.3.2, 8.4.1(c), 12.1.1(1), 15.6.1(d)
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
no
Mitigating circumstances
No previous non-compliance, cooperation and a remediation programme; 20% discount for early settlement.

Original amount 51,000 USD, converted at the ECB reference rate of 24 Nov 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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26 Aug 2025 UHY James Chartered AccountantsADGM: allegedly 20,400 USD fine for audit firm UHY James over unresolved screening alerts United Arab EmiratesInternal controls €17,502

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the registered auditor in ADGM, a branch of a foreign company, allegedly 20,400 USD for anti-money laundering failings between February 2022 and February 2024. In seven of 28 customer files reviewed, 397 screening alerts relating to four customers remained unresolved after a change of screening software, positive matches were dismissed without adequate justification, media reports alleging possible evasion of non-UAE sanctions by one customer were missed, the business risk assessment contained no assessment of targeted financial sanctions risk, and the source of funds and wealth of politically exposed persons was not verified. Without the 20% discount for early settlement the fine would have been 25,500 USD.

What organisations can take from it

Screening alerts must be resolved and closed with a documented rationale, especially after a system change.

Relevance to training and awareness

Name and sanctions screening: resolving and documenting alerts

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 6.1.1, 7.1.1, 7.1.2(1)(a), 7.1.3, 8.3.1(1)(b), 8.3.2, 8.4.1(c), 8.6.1, 11.2.1(1); Art. 21 Cabinet Decision No. 74 of 2020
Action
Fine
Status of proceedings
final
Sector
Other
Repeat case
no
Mitigating circumstances
No previous breaches of the AML rules, cooperation and substantial remediation (15% reduction); 20% discount for early settlement; the failings concerned only the ADGM entity and no other entities of the UHY group.

Original amount 20,400 USD, converted at the ECB reference rate of 26 Aug 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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18 Aug 2025 Morpheus Software Technology FZE (Fuze)VARA sanctions crypto provider Fuze over AML failings and activity outside its licence United Arab EmiratesInternal controls Fine

An investigation by the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator) that began on 15 April 2025 found failures in the anti-money laundering programme, governance, compliance and internal controls of Morpheus Software Technology FZE (Fuze), licensed since October 2023. The company had also intentionally carried out virtual asset activities in breach of its licence conditions and failed to disclose material facts to the regulator. VARA imposed a fine of an undisclosed amount, issued a cease-and-desist order according to its enforcement list, and ordered the appointment of a Skilled Person to oversee remediation.

What organisations can take from it

Licensed providers must stay within the scope of their licence and disclose material facts to the regulator – otherwise fines and external monitoring follow.

Relevance to training and awareness

AML programme, licence boundaries and disclosure to the regulator

Authority / court
Virtual Assets Regulatory Authority (VARA), Dubai
Area of law
Money laundering and terrorist financing · Internal controls
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
The company accepted the findings and proposed a remediation plan.
Published
18 Aug 2025

Checked against the official source on 3 Oct 2026 · Direct link

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31 Jul 2025 Gomti ExchangeCBUAE revokes Gomti Exchange's licence over AML and sanctions failings United Arab EmiratesInternal controls Other

The Central Bank of the UAE (CBUAE) revoked the licence of the exchange house Gomti Exchange and struck it off the register (Article 137 of Decretal Federal Law No. 14 of 2018). Examinations had found significant failures by the company to comply with the framework for combating money laundering and the financing of terrorism and illegal organisations and with the sanctions framework.

What organisations can take from it

For exchange houses, anti-money laundering and sanctions compliance are at the core of licence obligations – significant gaps can lead to the loss of authorisation.

Relevance to training and awareness

AML and sanctions compliance at exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018 regarding the Central Bank and Organisation of Financial Institutions and Activities
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
31 Jul 2025

Checked against the official source on 3 Oct 2026 · Direct link

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30 Jul 2025 Al Nahdi ExchangeCBUAE revokes Al Nahdi Exchange's licence over AML and sanctions failings United Arab EmiratesInternal controls Other

Central Bank examinations found significant failures by the exchange house to comply with the framework for combating money laundering, terrorist financing and illegal organisations and with sanctions requirements. The CBUAE revoked the licence and struck the exchange house off the register.

What organisations can take from it

Where AML and sanctions compliance is seriously deficient, payment service providers face not just a fine but the end of their licence.

Relevance to training and awareness

AML and sanctions compliance in exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 137 Decretal Federal Law No. (14) of 2018 regarding the Central Bank and Organisation of Financial Institutions and Activities
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
30 Jul 2025

Checked against the official source on 3 Oct 2026 · Direct link

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10 Jul 2025 Bank (anonymisiert)CBUAE: AED 3m on a bank for breaching AML requirements United Arab EmiratesInternal controls €697,653

Central Bank examinations found that an unnamed bank had not complied with the CBUAE's instructions implementing the anti-money laundering law. The CBUAE imposed a financial sanction of AED 3,000,000.

What organisations can take from it

Supervisory instructions on AML are binding – examinations uncover implementation gaps and lead to financial sanctions.

Relevance to training and awareness

Implementing supervisory AML instructions in banks

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 14 Federal Decree Law No. (20) of 2018 on AML/CFT; Art. 137 Decretal Federal Law No. (14) of 2018 regarding the Central Bank
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
10 Jul 2025

Original amount 3,000,000 AED, converted at the ECB reference rate of 10 Jul 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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17 Jun 2025 Sundus ExchangeCBUAE revokes Sundus Exchange's licence and fines it AED 10m over AML breaches United Arab EmiratesInternal controls €2.35m

The Central Bank of the UAE (CBUAE) revoked the licence of the exchange house Sundus Exchange, struck it off the register and fined it AED 10 million under Article 14 of the anti-money laundering law (Federal Decree Law No. 20 of 2018). The measures were based on examination findings of failures and breaches of the framework for combating money laundering and the financing of terrorism and illegal organisations.

What organisations can take from it

For payment and exchange businesses, anti-money laundering breaches can lead to a fine and loss of licence at the same time.

Relevance to training and awareness

AML obligations of exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 14 Federal Decree Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
17 Jun 2025

Original amount 10,000,000 AED, converted at the ECB reference rate of 17 Jun 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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1 May 2025 MBK Auditing L.L.CFSRA (ADGM): allegedly USD 14,080 on audit firm MBK Auditing for AML failings United Arab EmiratesCustomer due diligence €12,380

From September 2022 to November 2023 the audit firm registered in ADGM, subject to AML duties as a DNFBP, lacked an adequate business risk assessment, did not sufficiently examine customers' ownership structures and businesses, omitted a customer risk assessment in one case and did not appoint a new MLRO in time. After a 20% discount for early settlement the FSRA allegedly imposed USD 14,080 (otherwise USD 17,600).

What organisations can take from it

Audit firms, as obliged entities, must also maintain their own risk assessment, customer due diligence and an MLRO.

Relevance to training and awareness

AML duties of audit firms as DNFBPs

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 Financial Services and Markets Regulations 2015 (ADGM); AML Rules 6.1.1, 7.1.1, 8.3.1, 8.3.2, 12.1.1 (ADGM AML Rules)
Action
Fine
Status of proceedings
final
Sector
Other
Mitigating circumstances
Early settlement (20% discount), full cooperation and substantial remediation.

Original amount 14,080 USD, converted at the ECB reference rate of 30 Apr 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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27 Feb 2025 Emirates Advocates LLPADGM: law firm Emirates Advocates loses AML registration after years without AML returns United Arab EmiratesInternal controls Order

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) withdrew, with effect from 27 February 2025, the law firm's registration as a designated non-financial business or profession (DNFBP) for anti-money laundering purposes, which it needs to operate in ADGM. The firm had not filed its annual AML returns for 2019 to 2023 and, in the regulator's view, lacked adequate systems and controls; fines had already been imposed in 2021 (10,000 USD for the missing 2019 return) and in 2023 (26,000 USD for the missing goAML registration). The Decision Notice of 21 January 2025 was not referred to the Appeals Panel.

What organisations can take from it

A law firm that persistently ignores its anti-money laundering duties risks not only fines but also its registration, and with it its business in the financial centre.

Relevance to training and awareness

Anti-money laundering duties for law firms and other DNFBPs

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 251 FSMR 2015; AML Rules 4.6.1, 15.2.1(1)(b), 15.7.1(2)(c), 15.7.2(1)(a) und (b)
Action
Order
Status of proceedings
final
Sector
Other
Repeat case
yes

Checked against the official source on 3 Oct 2026 · Direct link

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19 Feb 2025 Wechselstube (anonymisiert, Sanktion vom 19.02.2025)CBUAE: AED 3.5m on an exchange house for AML breaches United Arab EmiratesInternal controls €913,388

Following an examination, the Central Bank found that an unnamed exchange house had not complied with its policies and procedures for combating money laundering and terrorist financing. The CBUAE imposed a financial sanction of AED 3.5 million.

What organisations can take from it

Exchange houses are under close AML supervision – gaps between policy and practice are punished with sums in the millions.

Relevance to training and awareness

AML prevention in exchange houses

Authority / court
Central Bank of the UAE (CBUAE)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 14 Federal Decree Law No. (20) of 2018 on AML/CFT
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
19 Feb 2025

Original amount 3,500,000 AED, converted at the ECB reference rate of 19 Feb 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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13 Dec 2024 Aarna Capital LimitedADGM: allegedly 504,000 USD fine for broker Aarna Capital over KYC and monitoring failures United Arab EmiratesCustomer due diligence €479,179

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the broker for professional clients allegedly 504,000 USD for inadequate anti-money laundering controls between June 2017 and January 2023. In a review of 42 client relationships the regulator found that twelve clients should have been rated high risk because of relevant risk factors, so enhanced due diligence and annual reviews did not take place; documentation, risk-based updating of customer data, transaction monitoring and procedures to detect suspicious activity were also inadequate. The regulator identified no specific instances of money laundering; without the 20% discount for early settlement the fine would have been 630,000 USD.

What organisations can take from it

A risk rating that is too lenient undermines every downstream control, from enhanced due diligence to periodic review.

Relevance to training and awareness

Customer risk rating and ongoing transaction monitoring

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 4.5.1(b), 4.5.3, 7.1.1, 8.1.2(1), 8.6.1(a), 14.2.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
No previous breaches of the AML rules (though earlier action over CRS reporting duties), cooperation and remediation including an external gap analysis (10% reduction); 20% discount for early settlement.

Original amount 504,000 USD, converted at the ECB reference rate of 13 Dec 2024.

Checked against the official source on 3 Oct 2026 · Direct link

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