AML fines in the UAE are tiered by violation type and who is penalised: administrative penalties against businesses now range from AED 10,000 to AED 5,000,000 per violation under the 2025 AML law, with criminal fines and imprisonment reserved for the most serious breaches. This page sets out the 2026 benchmark ranges by violation, what triggers each tier, and the compliance steps that keep a UAE business clear of them.
The law changed in 2025: what replaced Decree-Law 20 of 2018
Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism is the current instrument. It repealed Federal Decree-Law No. 20 of 2018, which had set the previous administrative fine floor at AED 50,000. Under the 2025 law:
- Administrative fines start at AED 10,000 per violation and can reach AED 5,000,000 per violation, and can be escalated where the same violation recurs within a year.
- Criminal penalties are separate and higher: money laundering by a natural person carries 1 to 10 years' imprisonment and a fine from AED 100,000 up to AED 5,000,000 — or the value of the criminal property, whichever is greater.
- Failing to file a Suspicious Transaction Report, whether deliberately or by gross negligence, carries imprisonment and a fine of AED 100,000 to AED 1,000,000.
- Tipping off carries imprisonment and a fine of at least AED 50,000.
The FTA continues to issue AML administrative penalties for Designated Non-Financial Businesses and Professions (DNFBPs) under Cabinet Resolution No. 16 of 2021, which sets fixed penalties per violation — for example AED 50,000 for failing to provide AML training to employees and AED 200,000 for failing to provide additional information requested by the FIU. Regulations and circulars made under the old law survive until superseded. Source: UAE Legislation — Federal Decree-Law No. 10 of 2025 · Source: Ministry of Justice portal
AML fine benchmarks by violation type (2026)
| Violation | Who it hits | Benchmark range (AED) | Source instrument |
|---|---|---|---|
| Failure to register on goAML | DNFBPs | 50,000 – 150,000 (fixed per violation under Cabinet Resolution 16/2021 schedule) | Cabinet Resolution No. 16 of 2021 |
| Failure to appoint an AML/CFT compliance officer | DNFBPs | 50,000 – 200,000 fixed per violation | Cabinet Resolution No. 16 of 2021 |
| No employee AML training | DNFBPs | 50,000 fixed | Cabinet Resolution No. 16 of 2021 |
| Inadequate customer due diligence (CDD) | Reporting entities | 10,000 – 5,000,000 (administrative, per violation) | Federal Decree-Law No. 10 of 2025, Art. 17 |
| Failure to file a Suspicious Transaction Report | Reporting entities | 100,000 – 1,000,000 plus imprisonment (criminal) | Federal Decree-Law No. 10 of 2025, Art. 28 |
| Tipping off | Any person | Imprisonment + fine of at least 50,000 | Federal Decree-Law No. 10 of 2025, Art. 29 |
| Breach of targeted financial sanctions instructions | Any person | Imprisonment + fine of at least 20,000 (criminal); TFS administrative fines under separate Cabinet decisions | Federal Decree-Law No. 10 of 2025, Art. 33 |
| Money laundering (offence) | Individuals and legal persons | Individuals: 1–10 years + 100,000–5,000,000. Companies: 500,000–50,000,000 | Federal Decree-Law No. 10 of 2025, Art. 26 |
Figures are the statutory ranges as enacted; supervisory authorities (Ministry of Economy for most DNFBPs, the FTA for certain tax-related AML duties, CBUAE and VARA for their sectors) apply them case by case, and aggravating factors push fines to the top of each band.
What pushes a fine to the top of its range
- Repeat violations within one year — the 2025 law escalates repeated breaches.
- Gross negligence in STR filing, not just procedural lapse.
- Trading while unregistered on goAML for an extended period.
- Concealing beneficial ownership or providing false records to a supervisor.
The five checks that keep a UAE business clear
- goAML registration is current — every DNFBP (real estate brokers, dealers in precious metals and stones, auditors, corporate service providers, law firms) must be registered on the goAML portal before it owes any reporting duty.
- A named compliance officer exists — appointment documented, with direct access to senior management.
- Sanctions and PEP screening runs on every client — at onboarding and on an ongoing basis, with records retained.
- STRs are filed within the deadline — as soon as reasonably practicable after suspicion forms; never tip off the customer.
- Training and KYC records are dated and filed — the two fixed-penalty magnets under Cabinet Resolution 16/2021 are missing training records and missing KYC files.
How fines are actually issued
A supervisory authority (Ministry of Economy, FTA, CBUAE, VARA, or a free zone regulator) inspects, identifies a violation, and issues a formal notice. The business gets a remediation window; the fine follows if remediation fails or the violation is material. Criminal referrals go through the Public Prosecution for the offences above. There is no 'warning-only' tier for goAML non-registration — registration failure is a fixed-penalty violation from day one.
How Finanshels helps
Finanshels provides AML compliance services for UAE DNFBPs: goAML registration, AML policy and risk assessment drafting, compliance officer support, screening setup and STR assistance. AML work is led by Krishna Subash Nair. If you have received an inspection notice or want a pre-inspection review, book a consultation.
Frequently asked questions
What is the maximum AML fine in the UAE for a business? AED 5,000,000 per violation under Federal Decree-Law No. 10 of 2025 for administrative penalties, with criminal fines against companies reaching AED 50,000,000 for the money laundering offence itself.
Did the AML fine ranges change recently? Yes. Federal Decree-Law No. 10 of 2025 repealed Federal Decree-Law No. 20 of 2018 and lowered the administrative floor from AED 50,000 to AED 10,000 while keeping the AED 5,000,000 ceiling, with escalation for repeat violations within a year.
What is the penalty for not registering on goAML? It is a fixed administrative violation under Cabinet Resolution No. 16 of 2021 — DNFBP registration failures sit in the AED 50,000–150,000 band, and supervisory authorities have issued these penalties in inspection campaigns.
Can directors be personally fined for AML violations? Yes for criminal offences — STR failures and money laundering carry personal imprisonment and fines for responsible individuals. Administrative penalties generally target the entity, though officers can face sanctions for directing or consenting to the violation.
How often does AML training need to be refreshed? The law requires ongoing training; the practical benchmark supervisors expect is at least annually, with records of attendance and content retained for inspection.
