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.
Click a bar to drill down one level.
Where?
by authority- Central Bank of the UAE (CBUAE) €52.6m 88 % · 7 cases
- Financial Services Regulatory Authority (ADGM) €6.53m 11 % · 9 cases
- Dubai Financial Services Authority (DFSA) €810,115 1 % · 2 cases
- Virtual Assets Regulatory Authority (VARA), Dubai – 0 % · 6 cases
What for?
by area of lawAll areas of law
Who?
by sectorAll sectors
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q4 2023 | 0 | – |
| Q1 2024 | 0 | – |
| Q2 2024 | 0 | – |
| Q3 2024 | 0 | – |
| Q4 2024 | 1 | €479,179 |
| Q1 2025 | 2 | €913,388 |
| Q2 2025 | 5 | €56.8m |
| Q3 2025 | 7 | €855,948 |
| Q4 2025 | 2 | €74,890 |
| Q1 2026 | 3 | €810,115 |
| Q2 2026 | 3 | – |
| Q3 2026 | 1 | – |
| Q4 2026 | 0 | – |
24 cases
24 Jul 2026 Shelbit General Trading L.L.CVARA sanctions Shelbit again for unlicensed crypto services, missing KYC and promotion 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.
Disregarding a cease-and-desist order leads to further sanctions – the regulator keeps monitoring the market after the first action.
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
- VARA: Notice of Fines – Shelbit General Trading L.L.C (24.07.2026) Press release of an authority
- VARA: Enforcement – Enforcement Actions (Einträge Shelbit General Trading L.L.C, 2026/07/24 und 2025/01/02) Enforcement database of an authority
- VARA Notice of Fines – Shelbit General Trading L.L.C (PDF, von vara.ae verlinkt) Press release of an authority
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 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.
Serving customers in a market requires a licence there – and local KYC obligations must be met regardless.
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
- VARA: Notice of Fines – MX Global LTD (MEXC) (22.06.2026) Press release of an authority
- VARA: Enforcement – Enforcement Actions (Eintrag MX Holdings Ltd (MEXC), 2026/06/17) Enforcement database of an authority
- VARA Notice of Fines – MX Global LTD (MEXC) (PDF, von vara.ae verlinkt) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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17 Jun 2026 Peken Global Limited (KuCoin)VARA: fine and cease-and-desist order against unlicensed Peken Global (KuCoin) Fine
Following VARA investigations, Peken Global Limited, trading as KuCoin, provided virtual asset broker-dealer and/or exchange services to customers in Dubai without a licence. VARA imposed fines of an undisclosed amount and ordered the immediate cessation of all unlicensed activities; other group entities were expressly not affected.
Anyone providing crypto services cross-border to customers in Dubai needs a licence there – regardless of where the platform is based.
Licensing requirement for crypto services in the target market
- Authority / court
- Virtual Assets Regulatory Authority (VARA), Dubai
- Area of law
- Capital markets and financial supervision
- Legal basis
- Federal Decree Law No. (10) of 2025 (AML/CFT/PF); Dubai Law No. (4) of 2022 Regulating Virtual Assets; Cabinet Resolution No. 111/2022; VARA Regulations und Rulebooks
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Mitigating circumstances
- Full cooperation and full compliance with the measures; intention to go through the licensing process.
- Published
- 24 Jun 2026
- VARA: VARA Notice of Fines – Peken Global Limited ('Kucoin') (Enforcement Notice, 24.06.2026) Press release of an authority
- VARA: Enforcement Notice of Fines – Peken Global Limited (PDF, verlinkt von vara.ae) Decision of an authority
- VARA: Enforcement Actions – Liste der Geldbußen (Eintrag Peken Global Limited (Kucoin), 2026/06/17) Enforcement database of an authority
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 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.
Even a licensed provider must keep its anti-money laundering programme aligned with its actual operations – the regulator reviews the entire period of operation.
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
- VARA: Notice of Fines – CoinMENA FZE (22.06.2026) Press release of an authority
- VARA: Enforcement – Enforcement Actions (Eintrag CoinMENA FZE, 2026/06/03) Enforcement database of an authority
- VARA Notice of Fines – CoinMENA FZE (PDF, von vara.ae verlinkt) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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2 Feb 2026 Ark Capital Management (Dubai) LimitedDFSA: allegedly USD 504,000 on Ark Capital Management over market abuse controls €425,676
The investment firm did not review alerts from its surveillance system adequately or promptly, so at least ten suspicious trading instances were not reported or reported late; it also failed to notify an agreed, potentially staged change in control. After a 30% settlement discount the DFSA allegedly imposed USD 504,000 (otherwise USD 720,000).
A surveillance system only helps if its alerts are reviewed promptly – and a staged acquisition of shares must still be notified.
Consistently working through trade surveillance alerts
- Authority / court
- Dubai Financial Services Authority (DFSA)
- Area of law
- Capital markets and financial supervision · Market abuse and insider dealing
- Legal basis
- Art. 90(2) Regulatory Law 2004 (DIFC); GEN Rules 11.10.12A, 5.3.20(a), 11.8.11(2), 4.2.3, 4.2.10 DFSA Rulebook
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Settlement (30% discount); USD 720,000 without settlement.
- Published
- 6 Feb 2026
Original amount 504,000 USD, converted at the ECB reference rate of 2 Feb 2026.
- DFSA: Decision Notice an Ark Capital Management (Dubai) Limited vom 02.02.2026 (PDF, Dateispeicher der DFSA-Website) Decision of an authority
- DFSA: The DFSA fines Ark Capital Management (Dubai) Limited USD 504,000 for market abuse systems and change of control reporting failings (Media Release, 06.02.2026, DFSA Rulebook) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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2 Feb 2026 Ed Broking (MENA) LimitedDFSA: USD 455,176 on reinsurance broker Ed Broking (MENA) for deceptive conduct €384,439
The reinsurance broker gave cedent insurers and reinsurers different premiums for the same placement, misled reinsurers about deductions and brokerage, and misled a client about the brokerage earned on 121 placements, partly using altered documents. In a settlement the DFSA allegedly imposed USD 455,176: USD 175,343 disgorgement (including interest) and a USD 279,833 penalty (USD 575,104 without settlement). The amount and the facts have not been confirmed against the primary source.
Undisclosed brokerage and inconsistent premium figures given to the contracting parties amount to deception – an early self-report reduces the consequences.
Transparency on brokerage and premiums in insurance distribution
- Authority / court
- Dubai Financial Services Authority (DFSA)
- Area of law
- Capital markets and financial supervision
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Self-report to the DFSA, internal investigation and restitution to clients; settlement (reduction from USD 575,104).
- Published
- 2 Feb 2026
Original amount 455,176 USD, converted at the ECB reference rate of 2 Feb 2026.
Checked against the official source on 3 Oct 2026 · Direct link
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8 Jan 2026 Wealthface LimitedADGM: Wealthface gives enforceable undertaking after capital and reporting breaches Other
The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) accepted an enforceable undertaking from the wealth manager and robo-adviser after its investigation found that between January 2023 and March 2025 the firm held insufficient liquid assets for most of the period and insufficient capital resources at the end of 2023 and 2024, calculated its capital requirement for three quarters of 2024 on an understated expenditure figure, did not prepare its 2023 financial statements under IFRS and filed them late, had no office in ADGM since the end of 2023 and paid supervision fees late. The firm admitted the alleged contraventions and undertook, among other things, to appoint an independent director within 60 days, to close any capital shortfall, to re-establish its head office and registered office in ADGM and to report monthly on its capital and liquid assets for one year. The undertaking contains no financial penalty.
Capital and liquidity requirements must be calculated continuously and on correct input figures, not only at the reporting date.
Ongoing monitoring of capital and liquidity
- Authority / court
- Financial Services Regulatory Authority (ADGM)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Section 235 FSMR 2015; PRU Rules 3.2.4(a), 3.7.2, 3.7.4(1); GEN Rules 4.5.1(1), 6.2.2, 6.6.2; FEES Rule 1.2.2
- Action
- Other
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Cooperation with the investigation; some of the contraventions (capital calculation and resources, IFRS accounts, office in ADGM) were already being remediated.
- Enforceable Undertaking der Wealthface Limited gegenüber der FSRA, angenommen am 8. Januar 2026 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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17 Dec 2025 Payward MENA Holdings LimitedADGM: allegedly 36,000 USD fine for Payward MENA Holdings over five years of late AML returns €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.
Regulatory returns need clear ownership and portal access that survives staff changes.
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.
- FSRA Final Notice an Payward MENA Holdings Limited vom 17. Dezember 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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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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18 Aug 2025 Morpheus Software Technology FZE (Fuze)VARA sanctions crypto provider Fuze over AML failings and activity outside its licence 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.
Licensed providers must stay within the scope of their licence and disclose material facts to the regulator – otherwise fines and external monitoring follow.
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
- VARA: Notice of Fines – Morpheus Software Technology FZE (18.08.2025) Press release of an authority
- VARA: Enforcement – Enforcement Actions (Eintrag MORPHEUS SOFTWARE TECHNOLOGY FZE (FUZE), 2025/08/18) Enforcement database of an authority
- VARA Notice of Fines – Morpheus Software Technology FZE (PDF, von vara.ae verlinkt) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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6 Aug 2025 Finanzierungsgesellschaft (anonymisiert)CBUAE fines finance company AED 600,000 for consumer protection breaches €140,793
The Central Bank of the UAE (CBUAE) fined an unnamed finance company AED 600,000 under Article 137 of the central bank law (Decretal Federal Law No. 14 of 2018). Examinations had found that the company had failed to comply with the central bank's Market Conduct and Consumer Protection Regulations and Standards.
Consumer protection rules in the financial sector are examined and sanctioned in their own right, not only anti-money laundering obligations.
Market conduct and consumer protection at finance companies
- Authority / court
- Central Bank of the UAE (CBUAE)
- Area of law
- Consumer protection and online retail
- Legal basis
- Art. 137 Decretal Federal Law No. (14) of 2018; CBUAE Market Conduct and Consumer Protection Regulations and Standards
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Published
- 6 Aug 2025
Original amount 600,000 AED, converted at the ECB reference rate of 6 Aug 2025.
- CBUAE: CBUAE Imposes a Financial Sanction on a Finance Company (Pressemitteilung, PDF, 06.08.2025) Press release of an authority
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 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.
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.
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
- CBUAE: CBUAE revokes licence of Gomti Exchange (Pressemitteilung, PDF, 31.07.2025) Press release of an authority
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 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.
Where AML and sanctions compliance is seriously deficient, payment service providers face not just a fine but the end of their licence.
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
- CBUAE: CBUAE revokes licence of Al Nahdi Exchange (Pressemitteilung, PDF, 30.07.2025) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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24 Jul 2025 The Open Network FoundationVARA: fine and cease-and-desist order against The Open Network Foundation (marketing) Fine
According to VARA's enforcement list, The Open Network Foundation breached the VARA Marketing Regulations. The list records a cease-and-desist order, a fine of an undisclosed amount and a public statement as the measures taken.
Foundations in the crypto sector are also subject to Dubai's marketing rules for virtual assets when they promote their offering there.
Rules for marketing virtual assets
- Authority / court
- Virtual Assets Regulatory Authority (VARA), Dubai
- Area of law
- Capital markets and financial supervision
- Legal basis
- VARA Marketing Regulations
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Telecoms, IT and software
- VARA: Enforcement Actions – Liste der Geldbußen (Eintrag The Open Network Foundation, 2025/07/24) Enforcement database of an authority
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 €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.
Supervisory instructions on AML are binding – examinations uncover implementation gaps and lead to financial sanctions.
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.
- CBUAE: CBUAE imposes a financial sanction of AED 3 million on a bank (Pressemitteilung, PDF, 10.07.2025) Press release of an authority
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 €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.
For payment and exchange businesses, anti-money laundering breaches can lead to a fine and loss of licence at the same time.
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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20 May 2025 Wechselstube (anonymisiert)CBUAE fines exchange house AED 200m over serious AML failings €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.
Weaknesses in an anti-money laundering framework can trigger very large fines.
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.
- CBUAE: CBUAE Imposes a financial sanction of AED 200 million on an Exchange House (Pressemitteilung, PDF, 20.05.2025) Press release 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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3 Apr 2025 AC Holding Limited (Cayman Islands, Hayvn-Muttergesellschaft)ADGM: 3.6m USD fine for Hayvn parent over payments routed through unregulated accounts €3.24m
The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the Cayman Islands parent company of the Hayvn group 3,600,000 USD for being knowingly concerned in unauthorised regulated activities of an unregulated ADGM special purpose vehicle and in breaches of permission by its ADGM subsidiary. Around 3,023 transactions for 241 group clients ran through the bank accounts of that vehicle, with deposits of about 507 million USD and payments of about 558 million USD, although the vehicle held no permission and was not subject to the ADGM anti-money laundering rules. The regulator increased the fine by 20%, partly because the parent did not fully disclose its use of the accounts to the regulator and withheld half of the fees owed to the appointed skilled persons.
A parent company is also liable when it knowingly routes client business through unregulated entities in a financial centre.
Licensing within a group: no processing through unregulated entities
- Authority / court
- Financial Services Regulatory Authority (ADGM)
- Area of law
- Capital markets and financial supervision
- Legal basis
- Sections 16, 17 und 20 i. V. m. Section 220 sowie Section 232 FSMR 2015
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Cooperation by the parent company and its audit and risk committee from mid-December 2023; the aggravating factors outweighed this.
- Liability of senior managers
- According to the Final Notice, the use of the accounts was not approved by the board but directed by the then CEO. Measures against individuals are not set out here.
Original amount 3,600,000 USD, converted at the ECB reference rate of 3 Apr 2025.
- FSRA Final Notice an AC Holding Limited (Cayman Islands) vom 3. April 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