This is Part 3 of our four-part series interpreting the 41 AML violations listed in Cabinet Resolution No. (71) of 2024 — a key regulation for DNFBPs, especially real estate companies.
In this part, we focus on Violations 21–30, which deal with:
- Failure to report suspicious activity
- goAML registration negligence
- Tipping off customers
- Shell bank dealings
- Early-stage sanctions missteps
📌 **Legal Notice:**
This content is for general informational purposes only. While InfoAML strives to ensure accuracy, this blog does not constitute legal advice or replace formal consultation with a licensed compliance expert or lawyer in the UAE.
Violations 21–30 Explained
Violation 21
“Failure of the facility to develop indicators to detect potential 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.”
Fine: AED 50,000 – 500,000
Tags: suspicious-transactions, red-flags, monitoring-rules
📌 Real estate companies must define and update internal indicators (red flags) that help staff identify and report suspicious activities.
Violation 22
“Failure of the facility to promptly submit reports of suspicious transactions and investigations to the Financial Intelligence Unit upon suspicion, based on reasonable grounds or suspicion that a crime was committed, or failure to provide any additional information the Unit requests.”
Fine: AED 100,000 – 500,000
Tags: STR, SAR, goAML-reporting, FIU
📌 You must file an STR or SAR as soon as you have reasonable suspicion — not when proof exists. And you must respond quickly to FIU follow-ups.
Violation 23
“Failure of the facility to register at the electronic system approved at the Financial Information Unit.”
Fine: AED 50,000 – 200,000
Tags: goAML-registration, FIU-system, regulatory-obligation
📌 Every real estate firm under the MOE must register on goAML. Failure to do so is a violation, even if you’ve never filed a report.
Violation 24
“Failure of the facility to appoint a compliance officer who has the appropriate competence and expertise to perform his duties.”
Fine: AED 50,000 – 200,000
Tags: compliance-officer, AML-responsibility, staffing
📌 You must designate a qualified Compliance Officer — not just assign the role to admin staff with no training.
Violation 25
“Failure of the facility to enable the compliance officer to perform any of the duties stipulated in Article (21) of the Executive Regulation.”
Fine: AED 50,000 – 500,000
Tags: compliance-officer-role, internal-controls, management-support
📌 Hiring a compliance officer is not enough — they must be given access, authority, and resources to fulfill their duties.
Violation 26
“Failure of the facility to keep any of the records, documents and data stated in the Decree-Law or the Executive Regulation, or to organize them in a manner that allows re-analysis and reconstruction of 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.”
Fine: AED 50,000 – 200,000
Tags: record-keeping, data-access, audit-readiness
📌 You must retain and organize AML records in a way that allows them to be retrieved and traced for investigations or audits.
Violation 27
“Failure to promptly apply decisions issued by the concerned authority in the State with respect to execution of UN Security Council's 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.”
Fine: AED 100,000 – 1,000,000
Tags: UN-sanctions, compliance-decrees, asset-freeze
📌 Companies must comply immediately with decisions to freeze assets or block transactions under UN Security Council resolutions.
Violation 28
“Disclosing, directly or indirectly, to the customer or any other person(s) that they have reported or are intending to report suspicious transactions, or the information and data relevant to such transactions, or that there is an investigation thereto.”
Fine: AED 100,000 – 500,000
Tags: tipping-off, confidentiality, STR-secrecy
📌 Never tell a client that you've filed a report or that their activity is being investigated. Doing so is a serious violation.
Violation 29
“Contacting the customer, whether directly or indirectly, to inform the customer with the procedures that were conducted concerning the latter without a written request from the relevant supervisory entity.”
Fine: AED 100,000 – 500,000
Tags: client-contact, regulatory-boundaries, AML-secrecy
📌 You may not contact a customer to explain compliance procedures unless officially asked by the authorities. Otherwise, it could be viewed as interfering.
Violation 30
“Dealing with shell banks in any way, whether through opening bank accounts, or accepting funds or deposits from such banks.”
Fine: AED 200,000 – 1,000,000
Tags: shell-banks, bank-due-diligence, high-risk-banking
📌 You must verify the legitimacy of any financial institutions you deal with. Shell banks — which have no physical presence or regulation — are strictly off-limits.
Final Thoughts – Part 3
These violations center around timely reporting, staff accountability, and protecting the integrity of investigations. Some are procedural, others carry high reputational risk — like tipping off or failing to act on international sanctions.
Even if your company has never filed an STR, being ready and compliant is non-negotiable.
Stay tuned for Part 4, where we’ll explore Violations 31–41, which focus on sanctions list handling, freezing procedures, and high-risk regulatory exposure.
Resources
Tags for this blog:
goAML, STR, tipping-off, reporting-obligations, UN-sanctions, compliance-officer, AML-records, cabinet-resolution-71, real-estate-AML, compliance-insights