title: United Arab Emirates — Legal & Litigation | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-arab-emirates/w7/ publisher: Asymmetric Intelligence ### W7 Legal & Litigation Confirmed confirmed 2026-06-27 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 2026 66 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. T1 [https://www.centralbank.ae/en/our-operations/enforcement/](https://www.centralbank.ae/en/our-operations/enforcement/) retrieved 2026-06-27 2. T1 [https://www.centralbank.ae/media/hhphe2s3/cbuae-imposes-financial-sanctions-of-aed-4-1-million-on-three-exchange-houses-en.pdf](https://www.centralbank.ae/media/hhphe2s3/cbuae-imposes-financial-sanctions-of-aed-4-1-million-on-three-exchange-houses-en.pdf) retrieved 2026-06-27 3. T3 [https://natlawreview.com/article/uae-central-bank-fines-foreign-bank-and-compliance-officer-money-laundering](https://natlawreview.com/article/uae-central-bank-fines-foreign-bank-and-compliance-officer-money-laundering) retrieved 2026-06-27 4. T3 [https://www.nortonrosefulbright.com/en-us/knowledge/publications/0eafbc05/aml-enforcement-on-the-rise](https://www.nortonrosefulbright.com/en-us/knowledge/publications/0eafbc05/aml-enforcement-on-the-rise) retrieved 2026-06-27