3.11 Sanctions against Persons Violating Reporting Obligations
Effective from 13/7/2023(AML-CFT Law Articles 15, 24, 25)
The AML-CFT Law provides for the following sanctions against any Financial Institutions, their managers or their employees, who fail to perform, whether purposely or through gross negligence, their statutory obligation to report a suspicion of money laundering or the financing of terrorism or of illegal organisations:
| • | Imprisonment and fine of no less than AED100,000 and no more than AED1,000,000; or |
| • | Any of these two sanctions. |
According to Article 15 of the AML-CFT Law, the requirement to report is in the case of suspicion or reasonable grounds to suspect a Crime. It should also be noted that the transactions or funds that are the subject of the suspicion may represent only part of the proceeds of the criminal offence, regardless of their value.
Likewise, the AML-CFT Law provides for sanctions against anyone who warns or notifies a person of a suspicious transaction report or reveals that a transaction is under review or investigation by the Competent Authorities, as follows:
| • | Imprisonment for no less than six months and a penalty of no less than AED100,000 and no more than AED500,000; or |
| • | Any of these two sanctions. |