Cabinet Resolution No.

(71) of 2024 Regulating Violations, Administrative

Penalties Imposed on Violators of Measures for Confronting Money
Laundering and Combating Financing of Terrorism Subject to the Control of
Ministry of Justice and Ministry of Economy

The Cabinet,
− Upon reviewing the Constitution; and
− Federal Law No. (1) of 1972, Concerning the Competences of the Ministries and the
Capacities of the Ministers, and its amendments; and
− Federal Decree-Law No. (20) of 2018, On Combating Money Laundering and the
Financing of Terrorism and Illegal Organisations, and its amendments thereof; and
− Cabinet Resolution No. (10) of 2019, Concerning the Executive Regulation of Federal
Decree-Law No. (20) of 2018 On Combating Money Laundering and the Financing of
Terrorism and Illegal Organisations, and its amendments thereof; and
− Cabinet Resolution No. (74) of 2020, Concerning the Terrorists Lists and
Implementation of UN Security Council Resolutions relating to Preventing and
Countering Financing Terrorism and Leveraging Non-Proliferation of Weapons of Mass
Destruction, and the Relevant Resolutions; and
− Cabinet Resolution No. (16) of 2021, Concerning the Unified List of Violations and
Administrative Fines Imposed on Violators of Measures for Confronting Money
Laundering and Combating the Financing of Terrorism Who are Under the Control of
the Ministry of Justice and Ministry of Economy; and
− Based upon the proposal submitted by the Minister of Finance and the Cabinet’s
approval,
Has resolved as follows:

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 1
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Article (1)
Definitions
Definitions stipulated in the aforementioned Cabinet Resolution No. (10) of 2019 shall be
applied. Otherwise, the following terms and expressions shall be accorded their designated
meanings, unless the context otherwise requires:
Ministry : Ministry of Justce or Ministry of Economy, as the case may
be.
Minister : Minister of Justice or Minister of Economy, as the case may
be.
Federal Decree-Law : Federal Decree-Law No. (20) of 2018, On Combating
Money Laundering and the Financing of Terrorism and
Illegal Organisations, and its amendments.
Executive : Cabinet Resolution No. (10) of 2019 Concerning the
Regulations Executive Regulations of Federal Decree-Law No. (20) of
2018, On Combating Money Laundering and the Financing
of Terrorism and Illegal Organisations, and its
amendments.
Designated Non- : Whoever engages in one or more of the commercial or
Financial Businesses professional businesses stipulated in Article (3) of the
and Professions Executive Regulations, who are Under the Ministry
oversight.

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 2
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Article (2)
Scope of Application
Provisions of this Resolution shall apply to Designated Non-Financial Businesses and
Professions upon violating any provision of the Decree-Law, the Executive Regulation or
the resolutions issued for its implementation.

Article (3)
Authority to Impose Administrative Penalties
1. The Ministry may impose one of the administrative penalties stipulated in Article (14)
of the Decree-Law or impose the administrative fines according to the list attached to
this Resolution, or both, upon committing any of the violations set forth in the list
attached to this Resolution.
2. The Minister shall designate a competent authority within the Ministry to be
responsible for imposing the administrative fines on the designated non-financial
businesses and professions, the procedures and controls to impose such fines.

Article (4)
Notification of the Administrative Penalty and Grievance Against it
1. The Ministry shall notify the violating party within the designated non-financial
businesses and professions of the Ministry’s decision to impose the administrative fine
thereon within twenty (20) working days as of the date of issuing the notice.
2. Any individual with a capacity or any stakeholder may grieve to the Minister or his
delegate against the administrative penalty within (30) thirty working days as of the
date of the notice of the penalty or the grievant knowledge, as the case may be,
provided that the grievance shall be substantiated and all supporting documents are
attached in accordance with the procedures applicable in the Ministry.

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 3
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
3. Upon considering the grievance, the Minister or his delegate may take any of the
following measures:
a. Deny the grievance and endorse the prescribed administrative penalty in case the
reasons and justifications on which the decision for which the grievance is
submitted are valid.
b. Amend the prescribed administrative penalty with another penalty from those
stipulated in Article (14) of the Decree-Law or the unified listed attached to this
Resolution, considering the violation, subject matter of the decision for which the
grievance is submitted and its proportionality to the nature of the activity and
volume of transactions of the facility, provided that the grievance shall not harm the
aggrieved party.
c. Cancel the prescribed administrative penalty in case the violation reasons are
removed or invalid.
4. The decision that is issued on the grievance shall be final, and failure to reply to the
grievance within (40) forty working days as of its submission date shall be deemed a
rejection of the grievance.
5. Appeal against the administrative fine decision imposed in accordance with the
provisions of this Resolution shall not be accepted prior to grievance and taking a
procedure with respect to such decision, or the lapse of the deadline for replying
thereto.

Article (5)
General Provisions
1. The fines imposed subject to the provisions of this Resolution shall be collected
according to the mechanism prescribed by the Ministry of Finance.

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 4
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
2. The Ministry may double the administrative fine value that is imposed on the Violator
once the violation is repeated.
3. Imposing the administrative fine under the provisions of this Resolution shall not
prevent the Ministry to impose any of the other administrative sanctions stipulated in
Article (14) of the Decree-Law.

Article (6)
Amendment of Fines
Subject to the provision of Article (14) of the Decree-Law, the Cabinet shall be competent
authority to amend the value of the administrative fines set forth in the list attached
thereto, whether by addition, deletion or amendment.

Article (7)
Executive Resolutions
The Minister shall issue the resolutions necessary to apply the provisions of this Resolution.

Article (8)
Repeals
The Cabinet Resolution No. (16) of 2021 Concerning the Unified List of Violations and
Administrative Fines Imposed on Violators of Measures for Confronting Money Laundering
and Combating the Financing of Terrorism Who are Under the Control of the Ministry of
Justice and Ministry of Economy. Any provision that violates or contradicts the provisions
of this Resolution shall be repealed.

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 5
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Article (9)
Resolution Publication and Entry into Force
This Resolution shall be published in the Official Gazette and shall enter into force as of the
day following the date of its publication.

Mohammed bin Rashid Al Maktoum

Prime Minister

Issued by Us:
Date: 2/ Muharram/ 1446 A.H.
Corresponding to: 08 July 2024 AD

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 6
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 The list Annexed to Cabinet Resolution No. (71) of 2024
Concerning the Unified List of Violations and Administrative Fines Imposed on
Violators of Measures for Confronting Money Laundering and Combating the
Financing of Terrorism Subject to the Control of the Ministry of Justice and Ministry
of Economy
No. Administrative Fine Amount
Legal
Violation (AED)
Reference
Minimum Maximum
Failure to set policies, measures
Article (20) of and internal controls approved
1 the Executive by the top management with 100,000 200,000
Regulation. the aim to combat committing
crimes.
Internal policies and
procedures are not consistent
Article (20) of
with the crime risks and the
2 the Executive 50,000 100,000
nature and size of the facility,
Regulation.
or failure to update them
continuously.
Failure to apply internal
policies, procedures, and
Article (20) of
controls to a branch of the
3 the Executive 50,000 100,000
facility or a subsidiary
Regulation.
company in which facility
holds a majority stake.
4 Article (20) of Failure to include any of the 50,000 200,000

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 7
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 the Executive provisions listed in Article (20)
Regulation. of the Executive Regulation in
the internal policies,
procedures, and controls.
Failure of the facility to take
necessary measures and
Article (4) Para procedures to identify, assess,
(1/B) of the understand, document, and
5 50,000 500,000
Executive continuously update crime
Regulation. risks in its field, as well as to
provide such information upon
request.
Failure of the facility to
consider all relevant risk
factors, such as risks of
customer. States, geographical
Article (4) Para regions, products and services,
(1/A) of the operations, and delivery
6 50,000 500,000
Executive channels of services and
Regulation. products before determining
the overall risk level and the
appropriate level of risk
mitigation measures that will
be applied.
Article (4), Failure of the facility to
7 50,000 1,000,000
Clause (2) of the undertake the actions and

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 8
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Executive procedures necessary to
Regulation. mitigate the risks identified
based on the results of the
National Risk Assessment or
the self-assessment process
given the nature and scale of
the violator’s business.
Failure of the facility to identify
and assess the risks that may
arise in the violator’s field of
Article (23) of
work when developing the
8 the Executive 50,000 500,000
services that the violator offers
Regulation.
or when conducting new
professional practices through
its facility.
Failure to undertake the
necessary customer due
diligence measures before
establishing the business
Article (6),
relationship or performing a
Clauses (1, 2, 3,
casual transaction in favour of
9 4 and 5) of the 50,000 200,000
the customer that is equal to or
Executive
more than (AED 55,000),
Regulation.
whether it is a sole or multiple
transactions that seem
connected, or upon making
casual transactions in the form
Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 9
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 of telegraph transfers equal to
or more than (AED 3,500) or
when suspicion exists about
the crime, data validity or
sufficiency to identify the
identity of the customer that
was previously obtained.
Failure of the facility to conduct
risk management procedures
Article (5),
with respect to circumstances
Clause (2) of the
10 where a customer would 100,000 500,000
Executive
benefit from the business
Regulation.
relationship before the
verification process.
Failure to verify - using
documents or data from a
reliable and independent
source - of the customer
Article (8), identity and the real
Clauses (1) and beneficiary or his deputy
11 (2) of the before or during the 50,000 200,000
Executive establishment of the business
Regulation. relationship or the account
opening, or before conducting
a transaction for a customer
with whom he has no existing
business relationship.
Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 10
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Failure to take necessary
measures to understand the
purpose, their nature, and
Article (8), nature of the business
Clauses (3, 4) of relationship of the customer
12 50,000 200,000
the Executive and the structure of ownership
Regulation. as well as controlling the
customer, or failure to obtain
information related to such
purpose whenever needed.
Failure to take reasonable
measures to address crime risks
arising from customer and the
Article (9) of the
business relationship to
13 Executive 50,000 200,000
identify and validate the
Regulation.
beneficial owner of legal
persons and legal
arrangements.
Failure of the facility to keep
Article (16) of the information obtained
14 50,000 200,000
the Decree-Law. through the execution of due
diligence measures.
Article (4), Failure to take enhanced due
Clause (2/B) of diligence measures to manage
15 100,000 500,000
the Executive high-risk when identified.
Regulation.

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 11
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Failure to apply enhanced due
diligence measures
proportionate to the level of
risk arising from business
Article (22), relationships or transactions
Clause (1) of the with natural or legal person
16 100,000 500,000
Executive from the States designated by
Regulation. the committee as high-risk or
with weak or deficient anti-
money laundering and
combating terrorism financing
systems.
Failure to apply
countermeasures or other
measures required by the
Article (22), supervisory authorities on their
Clause (2) of the own or as specified by the
17 100,000 500,000
Executive committee with respect to
Regulation. high-risk States or those with
weak or deficient anti-money
laundering and combating
terrorism financing systems.
Failure of the facility to set
Article (15) of systems or take appropriate
18 the Executive measures to manage risks or 50,000 200,000
Regulation. determine whether the
customer or the beneficial
Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 12
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 owner is foreign or citizen, a
politically exposed person or
an individual who has
previously held a prominent
position in an international
organization.
Failure of the facility to conduct
ongoing auditing and
monitoring of the continuing
business relationship to ensure
that documents, data, or
Article (7) of the information obtained under
19 Executive customer due diligence 50,000 500,000
Regulation. measures are up-to-date and
relevant. This occurs through
reviewing the registers and
books, especially the registers
and books of high-risk
customer categories.
Failure to abide by measures
Article (19) of and procedures when relying
20 the Executive on a third party to conduct 50,000 200,000
Regulation customer due diligence
measures.
Article (16) of Failure of the facility to develop
21 50,000 500,000
the Executive indicators to detect potential

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 13
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Regulation. criminal activity to report
suspicious transactions and to
continuously update such
indicators according to the
development and
diversification of methods to
commit such suspicious
transactions, while complying
with instructions issued by
supervisory authorities or the
Unit in this respect.
Failure of the facility to
promptly submit reports of
suspicious transactions and
investigations to the Financial
Articles (15) and Intelligence Unit upon
22 (17) of the suspicion, based on reasonable 100,000 500,000
Decree-Law. grounds or suspicion that a
crime was committed, or
failure to provide any
additional information the Unit
requests.
Article (17), Failure of the facility to register
Clause (1), and at the electronic system
23 Article (20), approved at the Financial 50,000 200,000
Clause (2) of the Information Unit.
Executive
Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 14
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Regulation.
Article (21) of Failure of the facility to appoint
the Executive a compliance officer who has
24 Regulation. the appropriate competence 50,000 200,000
and expertise to perform his
duties.
Article (21) of Failure of the facility to enable
the Executive the compliance officer to
25 Regulation. perform any of the duties 50,000 500,000
stipulated in Article (21) of the
Executive Regulation.
Article (24), Failure of the facility to keep
Clauses (1), (3) any of the records, documents
and (4) of the and data stated in the Decree-
Executive Law or the Executive
Regulation. Regulation, or to organize them
in a manner that allows re-
analysis and reconstruction of
26 50,000 200,000
individual transactions, data
analysis, and tracing financial
operations according to the
specified periods, or the failure
to make the same promptly
available for relevant entities
upon request.
27 Article (16) Para Failure to promptly apply 100,000 1,000,000

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 15
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 (1/E) of the decisions issued by the
Decree-Law. concerned authority in the
and Article (60) State with respect to execution
of the Executive of UN Security Council's
Regulation. resolutions issued under
Chapter Seven of the UN
Charter to prevent and
suppress terrorism and its
financing, prevention and
suppression of mass
destruction weapons
proliferation and suspension
and its financing and other
relevant resolutions.
Article (18) of Disclosing, directly or
the Executive indirectly, to the customer or
Regulation. any other person(s) that they
have reported or are intending
to report suspicious
28 100,000 500,000
transactions, or the
information and data relevant
to such transactions, or that
there is an investigation
thereto.
Article (39) of Contacting the customer,
29 the Executive whether directly or indirectly, 100,000 500,000
Regulation. to inform the customer with
Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 16
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 the procedures that were
conducted concerning the
latter without a written request
from the relevant supervisory
entity.
Article (14) of Dealing with shell banks in any
the Executive way, whether through opening
30 Regulation. bank accounts, or accepting 200,000 1,000,000
funds or deposits from such
banks.
Article (14) of Open or keep bank accounts
the Executive under nickname, pseudonym
31 200,0000 1,000,000
Regulation. or fake name, or with numbers
other than their owners names.
Article (44) of Failure to comply with the
the Executive instructions, regulations, and
Regulation. forms concerning crime
combating set by supervisory
authorities, or failure to
respond to request for
32 50,000 1,00,000
information regarding the
verification of compliance with
the provisions of the Decree-
Law, the Executive Regulation
and the resolutions issued in
implementation thereof from

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 17
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 the part of the facilities under
control.

Article (21) Failure of the facility to register

Clause (1) of at the website of the Executive
Cabinet Office for Control and Non-
Resolution No. Proliferation with the aim of
(74) of 2020. receiving notifications related
33 to the new designation, re- 50,000 1,000,000
designation as well as updating
or de-listing notifications
issued by the Security Council,
the Sanctions Committee, or
the Council of Ministers.
Article (21) Failure to constantly verify
Clause (2) of databases and transactions and
Cabinet compare them with the names
Resolution No. on the lists issued by the
34 (74) of 2020. Security Council, the Sanctions 50,000 1,000,000
Committee or the local lists, as
well as upon being informed of
any changes in any of these
lists.
Article (21) Failure of the facility to freeze
Clause (3) of funds under the local penalties
35 500,000 1,000,000
Cabinet list and the local lists promptly
Resolution No. when any match appears and
Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 18
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 (74) of 2020. without any prior warning.

Article (21) Failure of the facility to enforce

Clause (4) of the decision to cancel the
Cabinet freeze, in compliance with the
36 Resolution No. relevant Security Council 50,000 100,000
(74) of 2020. resolutions or Cabinet
decisions regarding the
issuance of local lists.
Article (15) Failure of the facility to
Clause (21) Para promptly report to the
(5/1) of Cabinet Executive Office for Control
37 50,000 100,000
Resolution No. and Non-Proliferation with
(74) of 2020. respect to freezing procedures
taken.
Article (15) and Failure of the facility to
Article (21) Para promptly report to the
(5/B) of Cabinet Executive Office for Control
Resolution No. and Non-Proliferation upon
(74) of 2020. determining any match with
38 the designated persons or 100,000 1,000,000
organizations, details of their
data and the actions taken in
compliance with the
requirements set by the related
Security Council Resolutions or
Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 19
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Cabinet decisions and the local
lists, including transactions that
are being attempted.
Article (21) Failure of the facility to
Paragraphs (5/C promptly report to the
and D) of Executive Office for Control
Cabinet and Non-Proliferation if the
Resolution No. facility one of its former
(74) of 2020. customers or any occasional
customer dealt with is a person
39 or organization included in the 100,000 1,000,000
Sanctions List or the local lists,
or when there is suspicion that
a current or former customer,
or someone associated with
the facility, is listed or has a
direct or indirect connection
with the listed person.
Article (21) Failure of the facility to promptly
Paragraph (5/E) report to the Executive Office for
of Cabinet Control and Non-Proliferation
Resolution No. upon failure to take any action
40 50,000 1,000,000
(74) of 2020. due to similarity of names and in
case removing that similarity has
failed through available or
accessible information.

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 20
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy
 Article (21) Failure of the facility to set and
Clause (6) of apply internal policies, controls
Cabinet and procedures pursuant to
41 100,000 1,000,000
Resolution No. provisions of the
(74) of 2020. aforementioned Cabinet
Resolution No. (74) of 2020.

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures 21
for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry
of Justice and Ministry of Economy