As part of a sweeping campaign to cement its status as a global leader in combating financial crime, the UAE has significantly intensified its enforcement efforts — issuing some of its heaviest AML fines in recent months. These actions have not gone unnoticed: in June, the EU removed the UAE from its list of high-risk jurisdictions from an AML perspective, signaling growing international confidence in the country’s financial crime oversight.
The move marks a major victory for the UAE, reflecting years of ongoing refinement and enhancement of its regulatory and enforcement landscape. The EU’s decision is a nod to these reforms — which include tightened oversight, greater financial transparency, and tougher enforcement. All of this comes as the UAE prepares for its upcoming Financial Action Task Force (FATF) mutual evaluation next year, which will provide the opportunity for UAE authorities to demonstrate the tangible impact of these reforms.
Record Crackdowns
The UAE has issued over Dh339 million in AML penalties on local exchange houses, foreign bank branches, and insurance companies in recent months. Among the most notable actions: one exchange house was hit with a Dh200 million fine and saw its branch manager permanently banned from the industry. Another exchange house faced a Dh100 million penalty, and most recently the Central Bank issued Dh 12.3 million in fines against six exchange houses for AML breaches.
These are not symbolic gestures — they’re clear signals. The UAE is showing it’s serious about transforming from what critics once called a "haven for illicit finance" into a model of financial transparency and enforcement.
A Clear Mandate: Compliance is Non-Negotiable
A pattern has emerged from these enforcement actions: widespread failures in how businesses monitor and report suspicious transactions, as well as in how they verify the identities of clients, partners, and beneficiaries. What's more, the UAE’s crackdown is extending beyond the banking sector, with regulators broadening their focus to industries that came under AML obligations much more recently. The message is clear: no matter your industry, every business must take compliance seriously.
To this end, the UAE is actively expanding its oversight of industries that could pose financial crime vulnerabilities — even those well beyond traditional finance. A prime example is the introduction of the region’s first licensing framework for financial influencers. This pioneering move marks a major regulatory milestone, aimed at bringing greater accountability to social media content creators who offer financial advice or promote investment products.
Experts believe this new framework will help curb potential investment fraud or misleading information, helping to prevent exploitation and ensuring that online financial content adheres to the country’s stringent compliance standards. This move comes at a crucial time, as investment fraud schemes have surged in recent years, with the Khaleej Times estimating that tens of thousands of UAE residents have lost savings to fake investment schemes.
A Cautionary Tale
One striking example of the need to regulate financial influencers is the case of Dubai-based influencer Aziz “Com” Mirza, who portrayed himself as a wildly successful serial entrepreneur and philanthropist. With over 800,000 Instagram followers, Mirza leveraged this online presence to promote various fraudulent investment opportunities — including a fake cryptocurrency dubbed “Habibi Coin.” In reality, his ventures operated as Ponzi schemes. His downfall began when a UAE resident reported losing $150,000 to one of his scams. Mirza was eventually arrested, having defrauded nearly 50 victims across the UAE, US, UK, and Canada through fake crypto offerings and questionable real estate projects.
This case underscores the need for regulatory oversight beyond traditional banking. As the UAE continues to expand its regulatory focus and enforcement actions, individuals and businesses operating across all industries are exposed to financial crime risks and face large-scale fines and penalties, as well as potential reputational damage. All this should be a compelling reminder to check and ensure your organisation’s AML measures are not only up to date but robust and in alignment with international and local standards.
What Do These New Developments Really Mean for Businesses?
With fines now reaching into the hundreds of millions of dirhams and industry bans being imposed on individuals, the regulatory stakes in the UAE have never been higher. This means that compliance can’t be viewed as simply a box-ticking exercise — but a critical pillar of risk management and smarter business. Now is the time to take proactive steps to strengthen your organisation’s AML controls and policies, as well as invest in enhancements in your risk management, due diligence, and screening capabilities.
These recent regulatory developments are part of a wider transformation in the UAE’s approach to fighting financial crime. Its recent National AML/CFT Strategy (2024–2027) — developed using the World Bank Group’s methodology and aligned with FATF best practices — marks a shift in regulatory focus at large. Focusing on risk-based compliance and measurable effectiveness, key pillars of the strategy include:
The UAE also recently released its latest National Risk Assessment (NRA), highlighting high-risk threat areas and predicate crimes such as fraud and drug trafficking. The report also identifies key AML priorities, including tackling more complex forms of financial crime — such as the misuse of legal entities — and addressing emerging threats like new forms of cybercrime.
For businesses operating in the UAE, staying current with the latest financial crime risks and evolving regulatory priorities is essential. It is also important to not simply meet baseline AML obligations — companies should take a proactive approach. This means regularly reviewing your compliance frameworks and ensuring you are equipped with the most advanced tools and technologies available.
Investing in modern AML systems not only helps meet regulatory expectations but also strengthens overall risk management and reinforces trust with regulators, partners, and customers alike.
Themis has also developed a FATF checklist to help both public sector and private sector organisations understand what they need to do to prepare for next year’s FATF evaluation. If you would like a consultation, please do let us know.
Stay on top of the ever-changing financial crime landscape by accessing the latest information on emerging criminal techniques and the risks associated with carrying out business with particular industries or in particular jurisdictions.
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