Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 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.
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Where?
by authority- Dubai Financial Services Authority (DFSA) €192,132 50 % · 2 cases
- Financial Services Regulatory Authority (ADGM) €192,122 50 % · 7 cases
What for?
by area of lawAll areas of law
Who?
by company- Anonymised companies €310,193 81 % · 5 cases
- FWS Group Ltd €44,179 11 % · 1 case
- UHY James Chartered Accountants €17,502 5 % · 1 case
- MBK Auditing L.L.C €12,380 3 % · 1 case
- Emirates Advocates LLP – 0 % · 1 case
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2023 | 2 | €88,527 |
| 2024 | 3 | €221,666 |
| 2025 | 4 | €74,061 |
| 2026 | 0 | – |
9 cases
24 Nov 2025 FWS Group LtdADGM: allegedly 51,000 USD fine for business centre operator FWS Group over missing customer checks €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.
A firm that outsources operations and compliance remains itself responsible for due diligence on all of its own customers.
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.
- FSRA Final Notice an FWS Group Ltd vom 24. November 2025 Decision of an authority
- ADGM FSRA Regulatory Actions and Sanctions (Durchsetzungsliste) Enforcement database of an authority
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 €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.
Screening alerts must be resolved and closed with a documented rationale, especially after a system change.
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.
- FSRA Final Notice an UHY James Chartered Accountants vom 26. August 2025 Decision of an authority
- ADGM FSRA Regulatory Actions and Sanctions (Durchsetzungsliste) Enforcement database of an authority
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 €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).
Audit firms, as obliged entities, must also maintain their own risk assessment, customer due diligence and an MLRO.
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.
- FSRA (ADGM): Final Notice an MBK Auditing L.L.C vom 01.05.2025 (PDF) Decision of an authority
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 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.
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.
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
- FSRA Final Notice an Emirates Advocates LLP vom 27. Februar 2025 (Widerruf der DNFBP-Registrierung) Decision of an authority
- ADGM FSRA Regulatory Actions and Sanctions (Durchsetzungsliste) Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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26 Sep 2024 an audit firm in DubaiDFSA: enforceable undertaking from audit firm over late audit documentation Other
Over three years the audit firm, a Registered Auditor, failed to assemble complete and final documentation for several audit files in time, contrary to ISA 230 and ISQM 1. The DFSA accepted an Enforceable Undertaking in which the firm committed to remedial action; no fine was imposed.
Audit files must be completed on time – they evidence the audit opinion and are subject to supervision.
Timely archiving of audit files
- Authority / court
- Dubai Financial Services Authority (DFSA)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- International Standard on Auditing 230 (Audit Documentation); International Standard on Quality Management 1
- Action
- Other
- Status of proceedings
- final
- Sector
- Other
- Mitigating circumstances
- The DFSA expressly acknowledged the firm's cooperation.
- Published
- 26 Sep 2024
- Dubai Financial Services Authority (DFSA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Sep 2026 · Direct link
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2 Aug 2024 an Abu Dhabi company service providerADGM: 32,000 USD fine for a company service provider over high-risk customer failings €29,534
The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the company service provider 32,000 USD because, from around October 2018 to December 2022, it did not adequately verify the source of wealth of customers it had rated high risk and entered into business relationships with them without senior management approval. Relevant policies existed but were not fully implemented; without the 20% discount for early settlement the fine would have been 40,000 USD.
Policies alone are not enough: for high-risk customers, documented senior management approval must be in place before the relationship begins.
Enhanced due diligence: source of wealth and senior management approval
- 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 8.4.1(c) und 8.4.1(e)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Repeat case
- no
- Mitigating circumstances
- No previous non-compliance, policies in place; full cooperation and remediation, including mandatory periodic AML training for all staff; 20% discount for early settlement; the failings concerned only this entity of the group.
Original amount 32,000 USD, converted at the ECB reference rate of 2 Aug 2024.
- Financial Services Regulatory Authority (ADGM), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Aug 2026 · Direct link
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18 Jul 2024 a corporate service provider in the DIFCDFSA: corporate service provider misled regulator with backdated documents – USD 210,000 €192,132
The company service provider, registered as a DNFBP, gave the DFSA documents that had been created and backdated after the event for an anti-money laundering risk assessment and refused access to records during a visit in March 2022. The DFSA imposed USD 210,000 and withdrew the DNFBP registration.
Documents created or backdated after the event and given to the regulator weigh more heavily than the gap they are meant to hide.
Honesty and cooperation with the regulator
- Authority / court
- Dubai Financial Services Authority (DFSA)
- Area of law
- Money laundering and terrorist financing
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Mitigating circumstances
- Settlement (30% discount); USD 300,000 without settlement.
- Liability of senior managers
- Measures against individuals are not set out here.
- Published
- 18 Jul 2024
Original amount 210,000 USD, converted at the ECB reference rate of 18 Jul 2024.
- Dubai Financial Services Authority (DFSA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 8 Oct 2026 · Company name anonymised since 18 Jul 2026 · Direct link
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13 Sep 2023 a UAE law firmADGM: 26,000 USD fine for a law firm over missing goAML registration €24,224
The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the law firm, registered as a designated non-financial business or profession (DNFBP) for anti-money laundering purposes, 26,000 USD because, despite numerous reminders since May 2019, it had not registered on the goAML system of the UAE Financial Intelligence Unit, through which suspicious transaction reports must be filed. The regulator found ineffective systems for detecting and reporting suspicious activity and a lack of cooperation, and increased the fine by 11,000 USD because the firm did not respond to correspondence, remained in breach and had previously breached the AML rules. The Decision Notice of 14 July 2023 was not referred to the Appeals Panel.
Without registration in the reporting system an obliged entity cannot file a suspicious transaction report; registration is a duty, not a formality.
Setting up the channel for suspicious transaction reports (goAML)
- Authority / court
- Financial Services Regulatory Authority (ADGM)
- Area of law
- Money laundering and terrorist financing · Suspicious activity reports
- Legal basis
- Section 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (b), 4.7.1(a); Federal Decree-Law No. 20 of 2018
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Repeat case
- yes
Original amount 26,000 USD, converted at the ECB reference rate of 13 Sep 2023.
- Financial Services Regulatory Authority (ADGM), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 13 Sep 2025 · Direct link
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20 Jul 2023 a UAE branch of a company service providerADGM: 72,000 USD fine for a company service provider over high-risk customer failings €64,303
The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the company service provider, a branch of a foreign company, 72,000 USD for customer due diligence failings between November 2019 and December 2021. For customers rated high risk, the source of funds and source of wealth were not adequately identified and verified and customer information was not reviewed periodically; certified true copies of identity documents were also missing. According to the notice, the failings concerned only this entity and the period before a change of ownership and management in the group; without the 20% discount for early settlement the fine would have been 90,000 USD.
For high-risk customers a statement of the source of funds and wealth is not enough; it must be evidenced and kept up to date.
Evidencing source of funds and source of wealth for high-risk customers
- 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 8.3.1(1)(d), 8.3.2, 8.4.1(c)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Repeat case
- no
- Mitigating circumstances
- No previous non-compliance, policies in place, cooperation and implementation of the remediation plan; 20% discount for early settlement.
Original amount 72,000 USD, converted at the ECB reference rate of 20 Jul 2023.
- Financial Services Regulatory Authority (ADGM), Veröffentlichung der Behörde (Entscheidung 2023) Decision of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 20 Jul 2025 · Direct link