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Avoiding AML Fines in 2023: Insights from Dubai's Recent $3M USD Penalty by DFSA

In a significant development, the Dubai Financial Services Authority (DFSA) has recently levied a substantial fine of USD $3,022,500 (AED 11,100,131) on Mirabaud (Middle East) Limited for its gaps in anti-money laundering (AML) systems and controls during the period between June 2018 and October 2021. This financial penalty also incorporates a disgorgement of USD $975,000 (AED 3,580,687), representing the economic gains Mirabaud obtained through fees and commissions due to non-compliance. Mirabaud settled, reducing the original fine from USD $3,900,000 (AED 14,322,750).

Although the DFSA did not conclusively label these transactions as money laundering, they highlighted significant AML deficiencies. Mirabaud’s AML policies and procedures proved ineffective, leading to violations and a failure to report suspicious transactions. The bank also failed to gather suitable evidence of customers’ financial market experience. Several key personnel have left Mirabaud, and the fine reflects the DFSA’s commitment to robust AML controls in the financial sector. This case serves as a reminder of the importance of AML compliance in maintaining financial system integrity.

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