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Violations & Fines for ML (Pt2)
Administrative Fine of AED 200,000 for the following violations:
  1. Failure to take enhanced due diligence measures to manage high risks
  2. Failure to notify the Financial Intelligence Unit of the suspicious transaction report
  3. Failure to provide the Financial Intelligence Unit with the additional information it requires regarding the suspicion matter reported
  4. Disclosing, directly or indirectly, to the customer or any other person(s) that they have reported or are intending to report a suspicious transaction
  5. Failure to implement the measures prescribed by the National Committee for Combating Money Laundering and the Financing of Terrorism and Illegal Organizations with respect to customers from high-risk countries
Administrative Fine of AED 1,000,000 for the following violations
  1. Dealing with shell banks in any way
  2. Opening or maintaining bank accounts without the account holder’s name
  3. Failure to take the measures regarding customers included in the international or domestic sanctions lists
In terms of administrative fines and the grievance mechanism, the resolution states that the ministry shall notify the violators of the DNFBPs included in the administrative fine decision signed on him within 15 days from the date of its issuance. The violator has the right to a grievance against the decision of the administrative fine to the minister or whoever he authorizes within 15 days from the date of his notification of the decision or his knowledge of it. The minister can take one of the following three measures when considering the issue of the grievance:
  • Upholding the prescribed administrative fine if the reasons and justifications are found to be valid.
  • Replacing the prescribed administrative fine with another penalty according to the nature of the violation and in line with the law and its executive regulations
  • Canceling the fine if the reasons for the violation have been removed or proven incorrect.
The decision on the grievance is considered final, and failure to respond to the grievance within 30 days from the date of its submission is considered a rejection of the grievance, and the appeal against the decision of the administrative fine signed before the grievance and rejection against it or the deadline for responding to it is not accepted.  

Source: Ministry of Economy