Personal Criminal Liability for Managers Under UAE AML Law: What You Need to Know
Delve into the introduction of personal criminal liability for senior managers under the UAE's 2025 AML legislation.
Strategically navigate corporate governance reforms to mitigate personal liability risks under the new AML legal regime.
One of the most significant and talked-about changes in the UAE's new Anti-Money Laundering (AML) law, Federal Law No. 10 of 2025, is the introduction of personal criminal liability for senior managers. This is a game-changer for corporate governance in the UAE and means that senior executives can no longer afford to take a hands-off approach to AML compliance. This guide explains what the new personal liability provisions mean for you.
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The Challenge: Moving Beyond Corporate Fines
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For too long, the penalties for AML failures have been seen by some as simply a cost of doing business. Large corporate fines, while significant, have not always been enough to change the culture of a company or to ensure that senior management takes AML compliance seriously. The introduction of personal criminal liability is designed to change that.
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The legal framework: Holding Individuals Accountable
The new law makes it clear that individuals, not just the companies they work for, can be held accountable for AML failures. This means that if a company is found to have breached the AML law, its senior managers can face criminal prosecution, which could result in a prison sentence and/or a significant personal fine.
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Who is at Risk?
The new personal liability provisions apply to any person who is responsible for the management of a company. This includes:
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- Directors
- Senior Executives
- Compliance Officers
- Anyone else who has a significant role in the management or control of the company
What Constitutes a Criminal Offense?
A manager can be held personally liable if they are found to have been involved in, or to have been negligent in preventing, a breach of the AML law by their company. This could include:
- Failing to implement an adequate AML compliance program.
- Failing to report a suspicious transaction.
- Turning a blind eye to money laundering or terrorism financing activity within the company.
- Actively participating in or facilitating a money laundering scheme.
The Importance of a "Due Diligence" Defense
The new law does provide for a "due diligence" defense. This means that a manager may be able to avoid personal liability if they can show that they took all reasonable steps to prevent the AML breach from occurring. This makes it more important than ever for senior managers to be able to demonstrate that they have taken a proactive and diligent approach to AML compliance.
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Conclusion: A New Era of Personal Responsibility
The introduction of personal criminal liability for managers is a clear signal that the UAE authorities are taking a much tougher stance on AML compliance. It is no longer enough for senior managers to simply delegate responsibility for AML to the compliance department. They need to be actively involved in overseeing the company’s AML compliance program and in fostering a culture of compliance throughout the organization.
The new personal liability provisions in the UAE AML law are a serious matter for all senior managers. At Nour Attorneys Law Firm, we can provide expert advice on your personal obligations under the new law and can partner with you to ensure that you have taken all reasonable steps to protect yourself from personal liability. Contact us for a confidential consultation.
Disclaimer: The information provided in this article is for general informational purposes only and does not constitute legal advice. Readers should seek professional legal advice tailored to their specific circumstances before making any decisions or taking any action based on the content of this article.
Nour Attorneys Team
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