This is the final part of our 4-part series interpreting Cabinet Resolution No. (71) of 2024, which lists 41 violations that can trigger administrative fines for DNFBPs, including real estate companies in the UAE.
In this segment, we cover Violations 31–41, which relate to:
- Sanctions list compliance
- Freezing procedures and reporting
- Shell bank restrictions
- Policy alignment with Cabinet Resolution No. 74 of 2020
These violations carry some of the heaviest penalties in the entire resolution — with maximum fines reaching AED 1,000,000.
📌 **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 31–41 Explained
Violation 31
“Open or keep bank accounts under nickname, pseudonym or fake name, or with numbers other than their owners' names.”
💰 Fine: AED 200,000 – 1,000,000
🏷 Tags: bank-accounts, transparency, identity-risk
📌 Opening or maintaining accounts with nicknames or false identifiers is a serious red flag and direct breach of AML transparency standards.
Violation 32
“Failure to comply with the instructions, regulations, and forms concerning crime combating set by supervisory authorities, or failure to respond to request for information regarding the verification of compliance with the provisions of the Decree-Law, the Executive Regulation and the resolutions issued in implementation thereof.”
Fine: AED 50,000 – 100,000
Tags: governance, compliance-response, audit-readiness
📌 Even if you’re following internal procedures, you must respond promptly to requests from regulators or risk being fined.
Violation 33
“Failure of the facility to register at the website of the Executive Office for Control and Non-Proliferation with the aim of receiving notifications related to the new designation, re-designation as well as updating or de-listing notifications issued by the Security Council, the Sanctions Committee, or the Council of Ministers.”
Fine: AED 50,000 – 1,000,000
Tags: sanctions, executive-office, registration
📌 You must register your company with the Executive Office to stay updated on sanctions changes. No excuses.
Violation 34
“Failure to constantly verify databases and transactions and compare them with the names on the lists issued by the Security Council, the Sanctions Committee or the local lists, as well as upon being informed of any changes in any of these lists.”
Fine: AED 50,000 – 1,000,000
Tags: sanctions-screening, list-verification, monitoring
📌 Real estate firms must screen names against all applicable sanctions lists — and do so regularly, not just during onboarding.
Violation 35
“Failure of the facility to freeze funds under the local penalties list and the local lists promptly when any match appears and without any prior warning.”
Fine: AED 500,000 – 1,000,000
Tags: fund-freeze, sanctions, enforcement
📌 If a match appears, you must freeze funds immediately — without notifying the client or waiting for instructions.
Violation 36
“Failure of the facility to enforce the decision to cancel the freeze, in compliance with the relevant Security Council resolutions or Cabinet decisions regarding the issuance of local lists.”
Fine: AED 50,000 – 100,000
Tags: unfreeze, compliance-update, sanctions
📌 Just as important as freezing is knowing when to unfreeze — if a person is de-listed or cleared, you must act accordingly.
Violation 37
“Failure of the facility to promptly report to the Executive Office for Control and Non-Proliferation with respect to freezing procedures taken.”
Fine: AED 50,000 – 100,000
Tags: reporting, sanctions, executive-office
📌 After freezing funds due to a match, you must inform the Executive Office right away.
Violation 38
“Failure of the facility to promptly report to the Executive Office for Control and Non-Proliferation upon determining any match with the designated persons or organizations, details of their data and the actions taken...”
Fine: AED 100,000 – 1,000,000
Tags: match-reporting, list-violation, compliance
📌 You must report any confirmed matches to designated individuals or entities — even if the transaction hasn’t yet completed.
Violation 39
“Failure of the facility to promptly report... if the facility or any of its former or current customers... is listed or has a direct or indirect connection with the listed person.”
Fine: AED 100,000 – 1,000,000
Tags: historical-screening, linked-entities, sanctions
📌 You are obligated to report both direct and indirect links with sanctioned parties — even past clients.
Violation 40
“Failure of the facility to promptly report... upon failure to take any action due to similarity of names and in case removing that similarity has failed through available or accessible information.”
Fine: AED 50,000 – 1,000,000
Tags: false-positive, name-match, risk-review
📌 If a name match can't be confirmed or ruled out due to limited information, you must still report that situation.
Violation 41
“Failure of the facility to set and apply internal policies, controls and procedures pursuant to provisions of the aforementioned Cabinet Resolution No. (74) of 2020.”
Fine: AED 100,000 – 1,000,000
Tags: policy-framework, internal-controls, governance
📌 Your internal AML program must reflect the detailed requirements of Cabinet Resolution No. (74). If it doesn’t — this violation applies.
Final Thoughts – Part 4
These final violations represent the most serious compliance breakdowns, often involving sanctions, terrorist financing risks, or failure to act on official government instructions.
For real estate companies, the key takeaway is this:
You don’t have to wait until a match appears — you must be screening, updating, and reporting constantly.
Resources
Tags for this blog:
sanctions-compliance, freezing-obligations, un-sanctions, executive-office, name-matching, false-positives, policy-failures, cabinet-resolution-71, dnfbp-uae, compliance-insights