Lessons from 41 AML Violations

Introduction: Why This Wrap-Up Matters

Over the past four blogs, we explored the 41 violations outlined in Cabinet Resolution No. (71) of 2024, a landmark regulation defining administrative fines for Designated Non-Financial Businesses and Professions (DNFBPs) that fail to meet Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) obligations in the UAE.

This final installment brings it all together. We’ll analyze patterns, fine structures, and practical compliance takeaways to help real estate companies, brokers, and other DNFBPs turn legal language into operational clarity.

Violation Categories at a Glance

To better understand the scope of violations, we grouped them into key thematic areas:

Category	Focus Area	Violations
Internal Controls & Policies	Governance, procedures, updates	1–4, 41
Risk Assessment Failures	Risk models, risk-based approach	5–8
CDD/EDD Gaps	Identity checks, beneficial ownership, PEPs	9–20
Reporting Obligations	goAML registration, SAR/STR filings	21–23
Compliance Officer Duties	Appointment, authority, enablement	24–25
Recordkeeping	Traceable documentation	26
Sanctions & Freezing	UN resolutions, name matching, notifications	27–40

Each group highlights a different failure point in the AML lifecycle, from onboarding and screening to escalation and enforcement.

Fine Ranges: Where the Real Risks Lie

Penalties under this resolution range from AED 50,000 to AED 1,000,000 per violation. But not all risks are equal:

• Highest fines (up to AED 1M) appear in:
  • Freezing failures (Violations 35–39)
  • UN resolution enforcement gaps (Violation 27)
  • Shell bank dealings or fake-name accounts (Violations 30–31)
• Lowest fines (AED 50K–100K) tend to relate to:
  • Governance/documentation gaps (Violations 1–4, 26)
  • Delays in compliance officer appointment or recordkeeping

This structured penalty system reflects how sanctions and reporting enforcement have become top government priorities.

The Most Common Traps for Real Estate Companies

Based on trends in real estate AML audits, here are the violations most frequently observed:

1. No documented internal risk assessment
2. Failing to verify beneficial ownership or PEP status
3. Appointing a compliance officer but not giving them access
4. No internal trail of goAML decisions (even when SAR wasn’t filed)
5. Overlooking freezing procedures or notifications when a name match appears

In many cases, violations occur not because of willful neglect, but because companies assume, "We're too small to be a target."

That assumption is both costly and incorrect.

How to Build a Stronger Compliance Posture

You don’t need a complex system to be compliant, but you do need a systematic approach. Here’s what helps:

• Risk Matrix
  Use a risk scoring model during onboarding and update it annually or after key events.
  
  
• Sanctions & PEP Screening
  Even manual tools are acceptable if logs are retained and matches are reviewed.
  
  
• Document Decisions
  If you choose not to file a SAR, record who reviewed it, why, and when.
  
  
• Empower Your Compliance Officer
  Don’t just appoint one. Give them access to systems, goAML portal, and internal records.
  
  
• Conduct Periodic Self-Audits
  Review a few client files monthly using the violation list as a checklist.

Final Thoughts

The 41 violations defined by Cabinet Resolution No. (71) of 2024 are more than legal formalities, they are practical flags that show regulators where real compliance risks live.

As enforcement increases in the UAE, especially across real estate and DNFBP sectors, your company’s ability to proactively manage risk will directly affect your business continuity, license security, and reputation.

Whether you’re operating manually or using an AML system, one thing is clear:

🔒 Compliance is no longer optional, it’s operational.

Download: Full List of AML Violations with Categories

Get the exact text of all 41 violations.

👉 Download the Full PDF Here

You might find the following related blogs helpful:

→ Understanding AML Violations & Penalties in the UAE – Part 4: Sanctions Compliance, Freezing Obligations & Internal Policy Failures (Violations 31–41)

→ Understanding AML Violations & Penalties in the UAE – Part 3: Reporting Failures, Tipping-Off, and Early Sanctions Missteps (Violations 21–30)

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