Yesterday, the Central Bank of the UAE (CBUAE) announced a financial penalty of AED 20 million (c. USD 5.45 million) against the UAE branch of a foreign bank following an investigation that revealed significant and repeated failures in the branch’s Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) and sanctions compliance programs.
Notably, CBUAE went further than fining only the bank itself; the Head of Compliance and Money Laundering Reporting Officer (MLRO) was personally fined AED 300,000 (c. USD 82,000) for failure to fulfil the responsibilities of his position.
This latest enforcement action reinforces some palpable messages:
- The UAE is committed to maintaining the highest international standards in the fight against money laundering, terrorist financing and sanctions evasion.
- CBUAE is using and will continue to use its supervisory and enforcement powers to drive improvements in governance, risk management and compliance across the financial sector.
- Institutions and senior individuals will be held accountable where standards fall short, with individual accountability a key tool in the UAE’s approach towards deterring misconduct.
In 2025 alone, CBUAE issued over AED 370 million (c. USD 101 million) worth of fines for AML/CFT failures. With the FATF Fifth Round Mutual Evaluation being held this month, it is very clear that the robust enforcement and accountability that was pivotal to the UAE’s removal from the FATF grey list in February 2024 continues.
Financial institutions operating in the UAE—and in particular branches of foreign banks whose operations are governed by home country AML/CFT and sanctions compliance programs that may not be sufficient to comply with the UAE’s AML/CFT expectations—risk very material institutional and personal consequences by not immediately identifying and remediating deficiencies.
