UAE Anti-Money Laundering / Compliance LawCabinet Resolution No.(71) of 2024 Regulating Violations, Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy

Article (1) Definitions Definitions stipulated in the aforementioned Cabinet Resolution No. (10) of 2019 shall be applied. Otherwise, the following terms and expressions shall be accorded their designated meanings, unless the context otherwise requires: Ministry : Ministry of Justce or Ministry of Economy, as the case may be. Minister : Minister of Justice or Minister of Economy, as the case may be. Federal Decree-Law : Federal Decree-Law No. (20) of 2018, On Combating Money Laundering and the Financing of Terrorism and Illegal Organisations, and its amendments. Executive Regulations : Cabinet Resolution No. (10) of 2019 Concerning the Executive Regulations of Federal Decree-Law No. (20) of 2018, On Combating Money Laundering and the Financing of Terrorism and Illegal Organisations, and its amendments. Designated Non- Financial Businesses and Professions : Whoever engages in one or more of the commercial or professional businesses stipulated in Article (3) of the Executive Regulations, who are Under the Ministry oversight.

-- 2 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 3

Article (4) Notification of the Administrative Penalty and Grievance Against it 1. The Ministry shall notify the violating party within the designated non-financial businesses and professions of the Ministry’s decision to impose the administrative fine thereon within twenty (20) working days as of the date of issuing the notice. 2. Any individual with a capacity or any stakeholder may grieve to the Minister or his delegate against the administrative penalty within (30) thirty working days as of the date of the notice of the penalty or the grievant knowledge, as the case may be, provided that the grievance shall be substantiated and all supporting documents are attached in accordance with the procedures applicable in the Ministry.

-- 3 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 4 3. Upon considering the grievance, the Minister or his delegate may take any of the following measures: a. Deny the grievance and endorse the prescribed administrative penalty in case the reasons and justifications on which the decision for which the grievance is submitted are valid. b. Amend the prescribed administrative penalty with another penalty from those stipulated in Article (14) of the Decree-Law or the unified listed attached to this Resolution, considering the violation, subject matter of the decision for which the grievance is submitted and its proportionality to the nature of the activity and volume of transactions of the facility, provided that the grievance shall not harm the aggrieved party. c. Cancel the prescribed administrative penalty in case the violation reasons are removed or invalid. 4. The decision that is issued on the grievance shall be final, and failure to reply to the grievance within (40) forty working days as of its submission date shall be deemed a rejection of the grievance. 5. Appeal against the administrative fine decision imposed in accordance with the provisions of this Resolution shall not be accepted prior to grievance and taking a procedure with respect to such decision, or the lapse of the deadline for replying thereto.

Article (4), Clause (2) of the 7

-- 8 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 9 procedures necessary to mitigate the risks identified based on the results of the National Risk Assessment or the self-assessment process given the nature and scale of the violator’s business. Executive Regulation. 500,000 50,000 Failure of the facility to identify and assess the risks that may arise in the violator’s field of work when developing the services that the violator offers or when conducting new professional practices through its facility.

Article (5) General Provisions 1. The fines imposed subject to the provisions of this Resolution shall be collected according to the mechanism prescribed by the Ministry of Finance.

-- 4 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 5 2. The Ministry may double the administrative fine value that is imposed on the Violator once the violation is repeated. 3. Imposing the administrative fine under the provisions of this Resolution shall not prevent the Ministry to impose any of the other administrative sanctions stipulated in

Article (6), Clauses (1, 2, 3, 4 and 5) of the Executive Regulation. 9

-- 9 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 10 of telegraph transfers equal to or more than (AED 3,500) or when suspicion exists about the crime, data validity or sufficiency to identify the identity of the customer that was previously obtained. 500,000 100,000 Failure of the facility to conduct risk management procedures with respect to circumstances where a customer would benefit from the business relationship before the verification process.

Article (9) Resolution Publication and Entry into Force This Resolution shall be published in the Official Gazette and shall enter into force as of the day following the date of its publication. Mohammed bin Rashid Al Maktoum Prime Minister Issued by Us: Date: 2/ Muharram/ 1446 A.H. Corresponding to: 08 July 2024 AD

-- 6 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 7 The list Annexed to Cabinet Resolution No. (71) of 2024 Concerning the Unified List of Violations and Administrative Fines Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of the Ministry of Justice and Ministry of Economy Administrative Fine Amount (AED) Violation Legal Reference No. Maximum Minimum 200,000 100,000 Failure to set policies, measures and internal controls approved by the top management with the aim to combat committing crimes.

Article (15) of the Executive Regulation. 18

-- 12 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 13 owner is foreign or citizen, a politically exposed person or an individual who has previously held a prominent position in an international organization. 500,000 50,000 Failure of the facility to conduct ongoing auditing and monitoring of the continuing business relationship to ensure that documents, data, or information obtained under customer due diligence measures are up-to-date and relevant. This occurs through reviewing the registers and books, especially the registers and books of high-risk customer categories.

Article (16) of the Executive 21

-- 13 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 14 criminal activity to report suspicious transactions and to continuously update such indicators according to the development and diversification of methods to commit such suspicious transactions, while complying with instructions issued by supervisory authorities or the Unit in this respect. Regulation. 500,000 100,000 Failure of the facility to promptly submit reports of suspicious transactions and investigations to the Financial Intelligence Unit upon suspicion, based on reasonable grounds or suspicion that a crime was committed, or failure to provide any additional information the Unit requests. Articles (15) and (17) of the Decree-Law. 22 200,000 50,000 Failure of the facility to register at the electronic system approved at the Financial Information Unit.

Article (20) of the Executive Regulation. 3 200,000 50,000 Failure to include any of the Article (20) of 4

-- 7 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 8 provisions listed in Article (20) of the Executive Regulation in the internal policies, procedures, and controls. the Executive Regulation. 500,000 50,000 Failure of the facility to take necessary measures and procedures to identify, assess, understand, document, and continuously update crime risks in its field, as well as to provide such information upon request.

Article (21) Para (5/B) of Cabinet Resolution No. (74) of 2020. 38

-- 19 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 20 Cabinet decisions and the local lists, including transactions that are being attempted. 1,000,000 100,000 Failure of the facility to promptly report to the Executive Office for Control and Non-Proliferation if the facility one of its former customers or any occasional customer dealt with is a person or organization included in the Sanctions List or the local lists, or when there is suspicion that a current or former customer, or someone associated with the facility, is listed or has a direct or indirect connection with the listed person.

Article (24), Clauses (1), (3) and (4) of the Executive Regulation. 26 1,000,000 100,000 Failure to promptly apply Article (16) Para 27

-- 15 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 16 decisions issued by the concerned authority in the State with respect to execution of UN Security Council's resolutions issued under Chapter Seven of the UN Charter to prevent and suppress terrorism and its financing, prevention and suppression of mass destruction weapons proliferation and suspension and its financing and other relevant resolutions. (1/E) of the Decree-Law. and Article (60) of the Executive Regulation. 500,000 100,000 Disclosing, directly or indirectly, to the customer or any other person(s) that they have reported or are intending to report suspicious transactions, or the information and data relevant to such transactions, or that there is an investigation thereto.

Article (44) of the Executive Regulation. 32

-- 17 of 21 --

Cabinet Resolution of 2024 Regulating Violations , Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating the Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy 18 the part of the facilities under control. 1,000,000 50,000 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.