Sets the schedule of administrative fines for DNFBPs supervised by the Ministry of Justice and the Ministry of Economy (lawyers, notaries, auditors, accountants, real estate brokers, dealers in precious metals and stones, and corporate service providers) that breach AML/CFT measures. Fines range from AED 50,000 to AED 1,000,000 per violation, doubled for repetition, replacing the 2021 unified list.
Cabinet Resolution No. 71 of 2024 is the fine schedule for DNFBPs supervised by the Ministry of Economy (now Ministry of Economy and Tourism) and the Ministry of Justice: real estate brokers, dealers in precious metals and stones, auditors and accountants, lawyers and notaries, and corporate service providers. Issued on 8 July 2024 and in force from the day after Official Gazette publication (16 July 2024), it repealed Cabinet Resolution No. 16 of 2021, the earlier unified list of violations (Article 8). Its definitions still refer to Cabinet Decision No. 10 of 2019, since the 2025 law and regulations came later, but the fines continue to apply under Article 39 of Federal Decree-Law No. 10 of 2025, which preserves implementing rules until replaced.
Article 3 lets the Ministry impose the fines in the attached table, the administrative penalties of the AML law, or both, through a competent body the Minister designates. Article 4 sets the procedure: the Ministry notifies the fine within 20 working days; the DNFBP may lodge a grievance with the Minister within 30 working days; the Minister may uphold, substitute or cancel the penalty and must reply within 40 working days, silence being rejection; the decision is final and court action is open only after the grievance route is exhausted. Article 5 lets the Ministry double a fine for repetition and keeps fines separate from other sanctions.
The table has 41 lines, each with a minimum and maximum. The lowest band is AED 50,000 to AED 100,000 (policies not matched to risk, ignoring supervisor instructions, not enforcing freeze cancellations, late reporting of freezes). The middle bands run AED 50,000 to AED 200,000 (no CDD before onboarding or for occasional transactions of AED 55,000 or more, beneficial owners not identified, no PEP systems, improper third-party reliance, no goAML registration, no qualified compliance officer, records not kept) and AED 100,000 to AED 500,000 (customer allowed to transact before verification, no enhanced due diligence for high risk or high-risk countries, late suspicious transaction reports, tipping off, contacting a customer about an investigation). The top bands reach AED 1,000,000: not mitigating risks identified in the national risk assessment (AED 50,000 to AED 1,000,000), not applying UN Security Council decisions, not registering with the Executive Office, not screening against sanctions lists, not reporting matches, dealing with shell banks or anonymous accounts (AED 200,000 to AED 1,000,000), and failing to freeze funds promptly on a match (AED 500,000 to AED 1,000,000).
Status: in force; no amendment recorded. It cross-refers to Cabinet Decision No. 74 of 2020 for the sanctions lines.
Designated non-financial businesses and professions under the supervision of the Ministry of Economy and Tourism or the Ministry of Justice: real estate brokers and agents, dealers in precious metals and stones, auditors and accountants, lawyers, notaries and independent legal professionals, and corporate and trust service providers such as Polaris, together with their compliance officers and managers.
| Article 1 | Adopts the definitions of Cabinet Decision No. 10 of 2019 and defines DNFBPs as those carrying on the businesses listed in Article 3 of the executive regulations under Ministry supervision. |
| Article 3 | The Ministry may impose the administrative penalties of the AML law, the fines in the attached table, or both; the Minister designates the body that imposes fines and sets its procedures. |
| Article 4 | Fine notified within 20 working days; grievance to the Minister within 30 working days; reply within 40 working days, silence meaning rejection; the decision is final and court action follows only after the grievance route. |
| Article 5 | Fines are collected by Ministry of Finance mechanisms, may be doubled for a repeated violation, and do not prevent other sanctions under the law. |
| Article 8 | Repeals Cabinet Resolution No. 16 of 2021 on the unified list of violations and any conflicting provision. |
| Article 9 | Published in the Official Gazette and in force from the day following publication. |
| Table | 41 violations with fine ranges from AED 50,000 to AED 1,000,000 per violation, covering policies, risk assessment, CDD, beneficial ownership, enhanced due diligence, PEPs, reporting, goAML registration, compliance officer, records, tipping off, shell banks and targeted financial sanctions. |
Fines per violation: AED 50,000 to AED 100,000 for mismatched policies, ignoring supervisor requests or late freeze reports; AED 50,000 to AED 200,000 for missing CDD, unidentified beneficial owners, no PEP systems, no goAML registration, no compliance officer or missing records; AED 100,000 to AED 200,000 for no approved policies; AED 100,000 to AED 500,000 for no enhanced due diligence, late suspicious transaction reports or tipping off; AED 50,000 or AED 100,000 up to AED 1,000,000 for sanctions screening, registration and reporting failures and for unmitigated national risks; AED 200,000 to AED 1,000,000 for shell banks or anonymous accounts; AED 500,000 to AED 1,000,000 for failing to freeze on a match. Doubled for repetition.
This is the price list behind every compliance recommendation we make to a DNFBP client, and behind our own programme. We rank remediation by the table: sanctions registration, screening and freezing first because those lines reach AED 1,000,000, then goAML registration and the compliance officer appointment, then the CDD and record-keeping lines at AED 50,000 to AED 200,000. When a client receives a Ministry notice we work the Article 4 clock: the grievance must be filed within 30 working days with the evidence of correction, and we prepare it on the basis that silence after 40 working days is a rejection that opens the court route. For our own files, the table is why we keep the screening log, the risk assessment and the training record ready for inspection rather than reconstructing them when asked.
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