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Issue 3 ·

Three compliance developments to act on this week

This week in one line: Sharjah Police has dismantled four networks behind Dh8.8bn of money laundering, US regulators have penalised Bank of America over reporting and sanctions controls, and the DFSA has fined a firm for providing company services without registering.

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Top story

Sharjah Police has dismantled a Dh8.8bn laundering network

On 15 October, Sharjah Police announced the arrest of 33 suspects of 12 nationalities, linked to four organised crime networks. The Attorney General put the amount laundered at Dh8.8bn (about $2.4bn), moved through bank accounts, digital wallets, international platforms and intermediary companies. Separately, authorities said they had secured Dh65bn of assets belonging to more than 30 companies, seized over Dh200m and audited about 3,000 wallets. Suspects allegedly posed as businesspeople and investors.

So what? The case spans banks, digital wallets, international platforms and intermediary companies, so every part of the regulated sector sits somewhere along the route the authorities describe.

Relevant if you are a bank, VASP, payments firm or DNFBP.

Sources: The National, Gulf News

Also this week

1. Bank of America hit with $1.2bn in penalties, including the largest in OCC history

On 13 October, the US Treasury announced penalties against Bank of America of more than $1.21bn (Dh4.4bn): a $1.2bn FinCEN penalty that credits a $750m penalty from the OCC, the largest in OCC history, plus an OFAC settlement of more than $11.6m. FinCEN found more than $5bn of suspicious transactions reported late and gaps in due diligence on foreign bank correspondent accounts, and the bank admitted wilfully violating the Bank Secrecy Act. OFAC cited 475 apparent sanctions violations.

So what? Timely suspicious activity reporting, correspondent due diligence and sanctions controls were what US regulators tested. Firms with US dollar exposure can use the case to benchmark their own.

Relevant if you handle US dollar payments or correspondent banking, or run your own sanctions screening.

Sources: US Treasury, OCC

2. DFSA fines a DIFC firm for providing company services without registering

On 15 October, the DFSA fined a DIFC firm $454,367 (Dh1.67m), a penalty made up of a fine and disgorgement. According to the DFSA, the firm acted as a formation agent and provided registered office and business addresses to 71 clients between August 2018 and February 2025, without being registered as a DNFBP. Its listed activities were management consultancy and document clearing, and it had also signed agreements with three free zones outside DIFC to facilitate company setup. The fine component was cut by 30% for settling. The DFSA said such businesses “can present elevated financial crime risks”.

So what? The DFSA calls the DNFBP regime a key part of its anti-money laundering framework and says it has zero tolerance for firms operating outside it. Firms that onboard clients through formation agents or registered-address providers have a reason to confirm the provider is registered.

Relevant if you onboard clients that use a formation agent or a registered-address provider.

Source: DFSA

On the radar

  • FRC fines Deloitte UK £6.05m over Go-Ahead audits. According to the Financial Reporting Council (8 October), Deloitte’s audits of Go-Ahead for 2016 to 2020 failed to meet the required standards, including a failure to challenge the wrongful retention of more than £30m of public money by two rail subsidiaries. The fine was cut from £11m by 45% for cooperation and early resolution, and Deloitte received a severe reprimand. Worth a check: if you work with auditors, that your files show how management’s explanations were challenged and what evidence supports them. FRC, Big4News
  • “Add me on WhatsApp” robocalls surge in the UK. The ICO says it received more than 3,600 complaints about the automated calls in September, nearly three times July’s level and a five-year high, and it is investigating. A representative of the Communications Crime Strategy Group, a telecoms industry fraud body, told the BBC the calls were most likely a recruitment scam that might involve money muling, though he had not followed up on the messages himself. Worth a check: that your staff and customer warnings cover unsolicited job offers involving receiving and moving money, which he linked to possible muling. BBC

Coming up

  • ACAMS Assembly MENA Virtual, 10–11 November: a two-day online conference on anti-financial crime for the region, carrying 12 ACAMS credits. See the programme, speakers and registration on the ACAMS event page.

Action of the week

Pick one company you onboarded through a formation agent or registered-address provider, and check that you hold evidence that the provider is registered or licensed for what it does.

SignPath Weekly is for general information only and is not legal, regulatory, tax, financial or compliance advice. It summarises the public sources linked in each item and may contain errors or become outdated, so check the primary source and take professional advice before acting. References to named companies report public actions as stated in the cited sources. The views expressed are the author's own and not those of any employer or organisation. To the fullest extent permitted by law, the author accepts no liability for loss arising from reliance on this newsletter. Spotted an error? Reply and I'll review and correct it.