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United Arab Emirates: Legal & Litigation

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Payments-sector legal action in the UAE is dominated by CBUAE administrative/financial enforcement rather than private litigation. In 2025 the CBUAE ran one of its most aggressive AML/CFT enforcement campaigns, with cumulative fines reported in the hundreds of millions of dirhams (~AED 370m+ since the start of 2025) across foreign bank branches, exchange houses, insurers and brokerages, including license revocations and personal sanctions on compliance officers/MLROs. Enforcement is grounded in Federal Decree-Law No. 20 of 2018 (AML/CFT) and the Central Bank Law, administered via the CBUAE Enforcement Department with appeals through the Grievances and Appeals Committee.

Standing sub-brief · as of 7 July 202666 words · last cycle 2026-06-27

Legal & Litigation

Federal Decree-Law No. 10 of 2025 introduced new personal liability and a lower evidentiary threshold for CBUAE administrative enforcement, underpinning fines exceeding AED 370 million levied since the start of 2025 with license revocations and personal sanctions on compliance officers and MLROs.

Outlook

The legal/enforcement trajectory is tracked as escalating, indicating continued administrative sanctions activity is likely as CBUAE deepens post-FATF-grey-list-exit supervisory intensity.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.centralbank.ae/en/our-operations/enforcement/retrieved
  2. T1https://www.centralbank.ae/media/hhphe2s3/cbuae-imposes-financial-sanctions-of-aed-4-1-million-on-three-exchange-houses-en.pdfretrieved
  3. T3https://natlawreview.com/article/uae-central-bank-fines-foreign-bank-and-compliance-officer-money-launderingretrieved
  4. T3https://www.nortonrosefulbright.com/en-us/knowledge/publications/0eafbc05/aml-enforcement-on-the-riseretrieved