Who was sanctioned, and for what?

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.

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

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.

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

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.

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

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

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.

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

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).

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.

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

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.

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

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.

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.

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

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.

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

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.

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

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.

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

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.

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

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.

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.

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

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.

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

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.

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

The Securities and Commodities Authority (SCA, the UAE's federal securities regulator) fined an unnamed company it had licensed AED 5 million. According to its investigation, the company had breached rules on combating money laundering, terrorist financing and the financing of illegal organisations and, together with a foreign company, had misled investors in the UAE by suggesting that the foreign company was licensed by the SCA, with the aim of misappropriating client funds.

Authority / court

Securities and Commodities Authority (SCA)

Area of law

Money laundering and terrorist financing

Legal basis

Vorschriften der VAE zur Bekämpfung von Geldwäsche, Terrorismusfinanzierung und Finanzierung illegaler Organisationen (in der Mitteilung nicht näher bezeichnet)

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Culpability

intentional

Published

25 Jul 2025

Original amount 5,000,000 AED, converted at the ECB reference rate of 25 Jul 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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.

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

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

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.

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

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.

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

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.

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

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).

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

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.

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.

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

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the provider of virtual asset trading and custody 3,000,000 USD and cancelled its Financial Services Permission. Between December 2021 and May 2024 it had dealt in virtual assets that were not accepted and exceeded its asset cap of 1 million USD, let client money run through accounts of an unregulated ADGM special purpose vehicle and of its parent company without formal agreements, maintained seven initially undisclosed client relationships without proper risk assessment and due diligence, and gave the regulator false and misleading information about bank accounts, clients and assets. The regulator considered the contraventions deliberate or at least reckless and increased the fine by 20% because of the false information.

Authority / court

Financial Services Regulatory Authority (ADGM)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Sections 17(1), 33, 214(4), 221 und 232 FSMR 2015; GEN Rules 2.2.1, 2.2.3, 2.2.9, 2.2.10, 2.2.11, 3.2.1, 3.3.1, 3.3.3, 3.3.7, 3.3.34, 8.1.2(6); COBS Rules 2.2.1, 14.2.1, 17.2.1; AML Rules 7.1.1, 7.1.2, 7.1.3, 8.3.1(1), 8.4.1

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Cooperation from mid-December 2023 and voluntary cessation of trading from 11 December 2023 under an enforceable undertaking; no previous non-compliance of a similar nature. The aggravating factors outweighed these.

Liability of senior managers

Measures against individuals are not set out here.

Original amount 3,000,000 USD, converted at the ECB reference rate of 3 Apr 2025.

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

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.

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

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.

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

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.

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

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.

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

Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Sep 2026 · Direct link

The Central Bank of the UAE (CBUAE) fined an unnamed bank operating in the UAE AED 5 million under Articles 89 and 137 of the central bank law (Federal Decree Law No. 14 of 2018) and Article 14 of the anti-money laundering law (Federal Decree Law No. 20 of 2018). The bank was also required to present the measure to the board of directors of its overseas headquarters; the release does not state what the breaches were.

Authority / court

Central Bank of the UAE (CBUAE)

Area of law

Capital markets and financial supervision

Legal basis

Art. 89 und 137 Federal Decree Law No. (14) of 2018 (Zentralbankgesetz); Art. 14 Federal Decree Law No. (20) of 2018 (AML/CFT)

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Published

16 Sep 2024

Original amount 5,000,000 AED, converted at the ECB reference rate of 16 Sep 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 16 Sep 2026 · Direct link

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.

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Aug 2026 · Direct link

Following an examination, the Central Bank found that the insurance broker had a weak compliance framework and did not meet its regulatory obligations. It revoked the broker's licence and struck it off the register.

Authority / court

Central Bank of the UAE (CBUAE)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Art. 22(2) Board of Directors Resolution No. 15 of 2013 Concerning Insurance Brokerage Regulations

Action

Other

Status of proceedings

unknown

Sector

Financial services and insurance

Published

26 Jul 2024

Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Jul 2026 · Direct link

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.

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.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 18 Jul 2026 · Direct link

The DIFC entity of a digital investment management group emailed almost 100,000 users an offer of shares in its parent company without an approved prospectus, withholding financial information while highlighting positive metrics. The DFSA imposed USD 191,100; the firm had halted the sale immediately after the regulator's warning and returned all monies. In parallel, the FSRA of ADGM separately sanctioned the sister company.

Authority / court

Dubai Financial Services Authority (DFSA)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Art. 90(2)(a) Regulatory Law 2004 (DIFC); Art. 11 und Art. 14 Markets Law 2012 (DIFC); Art. 41B Regulatory Law

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Immediate halt of the offer and return of all monies; settlement (30% discount); account taken of the parallel ADGM sanction.

Published

21 May 2024

Original amount 191,100 USD, converted at the ECB reference rate of 16 May 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 16 May 2026 · Direct link

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the operator of an investment and trading app 122,500 USD and required it to have its governance, systems and controls reviewed by an independent third party. In April and May 2023 the firm used emails (the first sent to 96,701 recipients) and its website to promote the purchase, through a special purpose vehicle, of shares in its own group from existing shareholders without an approved prospectus. The regulator considered the conduct reckless rather than deliberate; because of mitigating factors, including the prompt reversal of the transactions without investor detriment, it reduced the fine by 30% and granted a further 30% discount for settlement.

Authority / court

Financial Services Regulatory Authority (ADGM)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Sections 58(1), 61(1), 232 und 35 FSMR 2015

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Culpability

negligent

Mitigating circumstances

Full cooperation, prompt reversal without investor detriment, prior notice of the plan to the regulator (though without legal advice), short duration, no previous similar non-compliance; a settlement on similar terms was also reached with another UAE authority.

Original amount 122,500 USD, converted at the ECB reference rate of 15 May 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 May 2026 · Direct link

The Central Bank of the UAE (CBUAE) revoked the licence of the insurance agency and struck it off the register. The reasons were a weak compliance framework and failure to meet regulatory obligations; the legal basis was Article 20 of Resolution No. 08 of 2011 on the regulation of insurance agents' business.

Authority / court

Central Bank of the UAE (CBUAE)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Art. 20 Resolution No. 08 of 2011 Concerning the Regulation of Insurance Agents Business

Action

Other

Status of proceedings

unknown

Sector

Financial services and insurance

Published

6 Feb 2024

Checked against the official source on 7 Oct 2026 · Company name anonymised since 6 Feb 2026 · Direct link

After acquiring a further brokerage business the broker lacked sufficient compliance resources, although senior management knew of the shortfall; the DFSA also found breaches regarding the timing of customer due diligence and the recording of communications (July 2020 to November 2022). Because of a settlement and an Enforceable Undertaking with an external compliance expert, the fine was reduced from USD 2,793,403 to USD 1,368,767.

Authority / court

Dubai Financial Services Authority (DFSA)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Art. 90(2)(a) Regulatory Law 2004 (DIFC); GEN Rules 4.2.4, 5.3.1, 5.3.9, 5.3.11; AML Rule 7.2.1; COB Rule 6.7.1 DFSA Rulebook

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Settlement and Enforceable Undertaking; no evidence of deliberate contraventions; fine reduced from USD 2,793,403 to USD 1,368,767.

Liability of senior managers

Senior management knew of the compliance staffing shortfall and did not address it; the source mentions no sanctions against individuals.

Published

29 Dec 2023

Original amount 1,368,767 USD, converted at the ECB reference rate of 22 Dec 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 26 Dec 2025 · Direct link

Between February 2018 and March 2021 the bank was unable to properly identify, assess and report suspicious client trading; it did not effectively supervise its outsourced trade surveillance, so trading by two clients with the characteristics of market abuse went unreported. The DFSA imposed USD 373,842; in 2021 it had temporarily prohibited the bank from handling orders of specific clients.

Authority / court

Dubai Financial Services Authority (DFSA)

Area of law

Capital markets and financial supervision · Market abuse and insider dealing

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Mitigating circumstances

Full cooperation with the investigation and prompt remediation of the control weaknesses.

Published

2 Nov 2023

Original amount 373,842 USD, converted at the ECB reference rate of 2 Nov 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Nov 2025 · Direct link

The issuer had issued a token without authorisation from the Virtual Assets Regulatory Authority (VARA, Dubai's virtual assets regulator), offered it for public sale and marketed it from Dubai. VARA therefore took enforcement action and directed the company to suspend distribution immediately and to stop issuance and marketing until approval was granted; VARA announced this on 4 October 2023. After concluding its investigation, VARA regarded the matters largely as technical non-compliance and declared the case resolved on 29 December 2023 following governance commitments by the company.

Authority / court

Virtual Assets Regulatory Authority (VARA), Dubai

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Regulation III.A.1 Virtual Assets and Related Activities Regulations 2023 (Platzierung und Vertrieb virtueller Vermögenswerte, Broker-Dealer-Lizenz); Administrative Order No. 01/2022 (Marketing, Advertising and Promotions Related to Virtual Assets)

Action

Order

Status of proceedings

unknown

Sector

Financial services and insurance

Mitigating circumstances

Full cooperation and remedial measures, including improved public disclosures; VARA classed the matters largely as technical non-compliance.

Published

4 Oct 2023

Checked against the official source on 7 Oct 2026 · Company name anonymised since 4 Oct 2025 · Direct link

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the provider of prepaid cards and money transfers 486,000 USD. Between March 2021 and June 2022 its anti-money laundering policies, risk assessments, customer due diligence (for example on expected payment volumes and residential addresses) and monitoring of suspicious transactions were inadequate, with the risk assessment and due diligence failings affecting all 16,210 customers, and semi-annual reports of the money laundering reporting officer (MLRO) to the regulator were missing; in addition, from May 2021 to November 2022 the firm enrolled 1,956 customers in a group personal accident insurance scheme without the required permission. The regulator identified no specific instances of money laundering; without the 20% discount for early settlement the fine would have been 607,500 USD.

Authority / court

Financial Services Regulatory Authority (ADGM)

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

Sections 17(1) und 232 FSMR 2015; AML Rules 4.1.1(1), 4.1.1(2)(a) und (d), 4.1.1(4), 6.1.1, 6.2.1(b)(i), 7.1.1(3)(b) und (e), 8.3.1(1)(c), 8.3.2(2), 12.4.3, 14.2.1

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Repeat case

no

Mitigating circumstances

No previous AML breaches, cooperation throughout including an independent third-party report, completed remediation (subject to verification by the regulator); 20% discount for early settlement.

Original amount 486,000 USD, converted at the ECB reference rate of 27 Sep 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 27 Sep 2025 · Direct link

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.

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 13 Sep 2025 · Direct link

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the branch of the fashion retailer, registered as a dealer subject to anti-money laundering duties (DNFBP), 13,500 USD in respect of its store trading under the main brand, because despite reminders since May 2019 it only completed its registration on the goAML reporting system for suspicious transaction reports after a Warning Notice in May 2023 and did not respond to the regulator's correspondence. Without the 10% discount for late settlement the fine would have been 15,000 USD; on the same day an identical Final Notice, also for 13,500 USD, was issued to the same company in respect of its store trading under another of the group's brands.

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

Retail and e-commerce

Repeat case

no

Mitigating circumstances

No previous AML breaches, prompt registration after the Warning Notice, no cash sales above 55,000 AED in the relevant period (lower risk); 10% discount for late settlement.

Original amount 13,500 USD, converted at the ECB reference rate of 11 Aug 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 11 Aug 2025 · Direct link

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.

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.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 20 Jul 2025 · Direct link