TRW & Co · Disputes & Arbitration
White-Collar Crime and Investigations in the UAE
White-collar crime in the UAE is prosecuted under federal law everywhere, including the DIFC and ADGM, and enforcement has sharpened since a new anti-money laundering law took effect in October 2025. Companies face corporate liability for fraud, bribery and laundering, while individuals can face travel bans and asset freezes from the first days of an investigation.
Key pointUAE law exempts a briber who reports the offence before it is discovered, but offers no deferred prosecution or plea deal for bribery and imposes no limitation period, so the decision to self-report is time-critical and cannot be postponed.
At a glance
Federal criminal law
The Crimes and Penalties Law and Criminal Procedure Law apply across the UAE, including the DIFC and ADGM, which have no criminal codes of their own.
New AML law
Federal Decree-Law No. 10 of 2025 replaced the 2018 law, added tax evasion as a predicate and lowered the knowledge threshold to reasonable suspicion.
Corporate liability
Companies are liable for crimes committed in their name or on their behalf by directors, representatives or agents, facing fines and confiscation.
Self-reporting exemption
A party to bribery who reports it before discovery can be exempted from punishment; no plea or deferred prosecution mechanism exists.
Prosecutor-led process
The Public Prosecution directs investigations and can order travel bans, detention and asset freezes before any charge is filed.
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What white-collar crime in the UAE covers
White-collar crime in the UAE covers financially motivated offences committed through business: fraud and deception, breach of trust and embezzlement, bribery in the public and private sectors, forgery, money laundering, market abuse, cyber-enabled fraud and, increasingly, tax evasion as a predicate for laundering. It also covers the investigations that precede charges, whether run by the police, the Public Prosecution, a financial regulator or the company itself.
For a business, the legal question usually arrives in one of three ways: an internal whistleblower report, a request or summons from an authority, or a commercial dispute in which the other side files a criminal complaint to gain leverage. Each demands a different first response, and mistakes in the first days are hard to undo because criminal procedure in the UAE moves quickly and is driven by the prosecutor.
The stakes are personal as well as corporate. Individuals can face detention, travel bans and asset freezes while an investigation runs, and companies can face fines, confiscation and regulatory action that follows them into banking relationships and licence renewals.
The legal framework
Criminal law is federal and applies throughout the UAE, including inside the DIFC and ADGM. The financial free zones have their own civil, commercial and regulatory laws, but they do not have their own criminal codes. A DIFC or ADGM firm suspected of fraud is investigated and prosecuted under federal law.
Core statutes
- Crimes and Penalties Law (Federal Decree-Law No. 31 of 2021, in force since 2 January 2022, as amended): fraud, breach of trust, embezzlement, forgery, public and private sector bribery, misuse of public funds and the general rules on corporate criminal liability.
- Criminal Procedure Law (Federal Decree-Law No. 38 of 2022, as amended): the powers of police and prosecutors, detention, travel bans, searches and the civil claim that a victim can attach to criminal proceedings.
- Anti-money laundering law: Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, which replaced the 2018 law in October 2025.
- Cybercrime law (Federal Decree-Law No. 34 of 2021): online fraud, unauthorised access, phishing and electronic forgery.
- Sector laws: capital markets, banking, insurance, virtual asset and commercial fraud legislation, each with its own offences and administrative penalties.
Who investigates
| Authority | Role | When you meet them |
|---|---|---|
| Public Prosecution (federal and emirate level) | Directs investigations, questions suspects, orders travel bans and freezes, decides whether to charge | Every criminal matter that proceeds beyond the police stage |
| Police, including Dubai Police economic crime units | Receives complaints, gathers evidence, takes initial statements | Complaints by counterparties, victims or employers |
| UAE Financial Intelligence Unit | Receives suspicious transaction reports through goAML; can suspend transactions and freeze funds for short periods | Bank account freezes; reporting obligations |
| Dubai Economic Security Centre, Abu Dhabi Accountability Authority, State Audit Institution | Investigate corruption and misuse of public funds in government-linked entities | Contracts with government and government-owned bodies |
| Central Bank of the UAE, Capital Market Authority (formerly SCA), VARA, DFSA and FSRA | Supervise licensed firms; impose administrative penalties; refer crimes to prosecutors | Regulated businesses, listed companies and virtual asset providers |
Regulators in the DIFC and ADGM can enforce only their own rules. Where they find evidence of a crime they pass it to the police or Public Prosecution, so a regulatory inquiry can become a criminal one without warning. Our page on regulatory investigations in the UAE covers the regulatory side.
Corporate liability, bribery and money laundering
Under the Crimes and Penalties Law a legal person is criminally responsible for offences committed in its name or on its behalf by its representatives, directors or agents. The company faces fines, confiscation and other measures rather than imprisonment, and the individuals involved remain personally liable. Government bodies are excluded from corporate liability.
Bribery and corruption
Bribery of public officials, foreign public officials and employees of international organisations is an offence, and so is bribery in the private sector. Intermediaries are caught. There is no general statutory regime for gifts and hospitality, so whether a benefit is lawful depends on intent and context; public employees are tightly limited in what they may accept. Facilitation payments are not permitted.
Two features of white-collar crime in the UAE surprise foreign companies. First, a briber or bribe-taker who reports the offence to the authorities before it is discovered can be exempted from punishment, which creates a strong incentive to self-report early. Second, there is no deferred prosecution agreement or plea-bargaining regime for bribery, and bribery offences are not subject to a limitation period.
Money laundering under the 2025 law
The 2025 AML law widened the net. A person may be liable where they should reasonably have known funds came from crime, not only where they knew. Tax evasion is now expressly a predicate offence, laundering through virtual assets and encryption technologies is addressed directly, and penalties were increased, many linked to the value of the criminal property. Contracts designed to frustrate seizure or confiscation are void.
The Financial Intelligence Unit can suspend a transaction for a short period and freeze funds pending prosecutorial action. For companies, the practical risk is a sudden account freeze while a counterparty's funds are investigated. See AML compliance in the UAE for the preventive obligations of banks, DNFBPs and virtual asset providers.
In the UAE the first statement given to police or prosecutors often shapes the whole case. Preparation before that interview is worth more than any later argument.
Running an internal investigation
Most allegations of white-collar crime in the UAE start inside the business. A finance manager notices unexplained payments, an auditor queries a supplier, or a whistleblower emails the board. How the company responds determines whether it controls the narrative or reacts to one written by the authorities.
Investigations onshore must respect UAE labour law, data protection rules and the limits of legal privilege. Lawyer confidentiality is protected under the professional rules governing advocates, but there is no settled onshore doctrine equivalent to English litigation privilege covering every internal report. Investigation reports should therefore be structured with disclosure risk in mind, and findings should be kept factual. The federal Personal Data Protection Law also affects how employee data, emails and devices are collected and reviewed.
Employment steps run in parallel. Suspension, interviews and any dismissal must follow the labour law and the employer's own policies, and a dismissal for misconduct needs evidence that would stand up before MOHRE and the courts. See workplace investigations in the UAE for the employment process.
Before interviewing anyone, image the relevant devices and email accounts and suspend routine deletion. Evidence lost after a company knew of a problem is treated harshly by prosecutors and regulators, and it weakens any later civil claim to recover the money.
How a criminal matter unfolds
- Complaint or referral. A victim, employer, bank or regulator files a complaint with the police or Public Prosecution, or the FIU refers a suspicious transaction.
- Police evidence gathering. Police take statements, request documents and may summon the suspect. Translations into Arabic are needed for any document relied on.
- Prosecution investigation. The prosecutor questions parties and witnesses, appoints experts such as forensic accountants, and may order a travel ban, detention or a freeze on assets.
- Charging decision. The prosecutor refers the case to the criminal court, closes it for lack of evidence, or in some offences accepts reconciliation where the law allows.
- Trial. The criminal court hears the case largely on the written file and expert reports. A victim may pursue a civil claim for compensation within the criminal case.
- Appeal and enforcement. Judgments can be appealed to the Court of Appeal and then the Court of Cassation. Confiscation and restitution orders follow a final judgment.
Timelines vary widely by emirate and complexity. Travel bans can remain in place throughout, so applications to lift or vary them, supported by guarantees, are a common early step.
Documents and evidence to secure
- Board and committee minutes, delegation-of-authority matrices and approval records for the transactions in question.
- Accounting ledgers, bank statements, payment approvals and supplier onboarding files, including beneficial ownership checks.
- Emails, messaging records and device images collected under a documented chain of custody.
- Contracts, agency and consultancy agreements, and evidence of services actually rendered.
- Gifts and hospitality registers, conflicts declarations and compliance training records.
- Prior audit findings, whistleblowing reports and how they were handled.
- Certified Arabic translations of key documents, since the prosecution file is in Arabic.
Where funds have been taken, early civil steps such as precautionary attachment may be needed alongside the criminal complaint; see emergency and interim relief in the UAE.
Risks and common mistakes
Filing a criminal complaint as a debt-collection tactic
Counterparties sometimes report a commercial dispute as fraud or breach of trust to pressure payment. Prosecutors increasingly recognise this and may close complaints that are civil disputes in disguise, but not before the other side has faced questioning or a travel ban. If you are the complainant, a weak complaint can damage your credibility and expose you to counter-claims. If you are the target, a prompt, well-documented response showing that the matter is contractual is often the fastest route to closure.
Attending a police summons unprepared
Statements are taken in Arabic, often through an interpreter, and the written record becomes central evidence. Individuals who attend without understanding the allegation, without documents, or without reviewing the translated record before signing can make admissions that are hard to retract. Obtain advice before attending, take a copy of key documents and insist on accurate interpretation. Where representation is required, we work alongside locally licensed advocates.
Ignoring the self-reporting window
The exemption for those who report bribery before it is discovered rewards speed. A company that discovers a suspicious payment and spends months deciding what to do may lose the benefit, especially if the FIU, a bank or a regulator raises it first. Boards should have a protocol that escalates credible allegations quickly and puts the self-reporting decision on the agenda early, with advice on how a report affects the individuals concerned.
Treating the DIFC or ADGM as a separate criminal jurisdiction
Firms in the financial free zones sometimes assume their regulator is the only authority they need to manage. Federal criminal law applies in both centres, and the DFSA and FSRA refer suspected crimes to the police and prosecutors. A regulatory investigation strategy that ignores parallel criminal exposure can produce admissions or documents that are later used in a prosecution.
Collecting evidence in breach of data protection or labour rules
Seizing personal phones, reading private messages or covertly recording staff can breach privacy, data protection and cybercrime laws, turning an investigator into a suspect. Use company-owned devices and systems where possible, rely on clear IT and monitoring policies, and document the legal basis for each collection step. The Personal Data Protection Law and, in the free zones, the DIFC or ADGM data protection rules also govern transfers of evidence abroad.
Where white-collar crime in the UAE typically arises
Enforcement patterns follow the economy. Because Dubai and Abu Dhabi are trading, property and financial hubs, the cases that most often reach prosecutors involve money moving through business channels rather than street-level fraud. Knowing the hotspots helps boards focus controls where allegations of white-collar crime in the UAE are most likely to surface.
- Trade-based laundering. Over- and under-invoicing, phantom shipments and circular trades through re-export businesses. Banks scrutinise trade finance documents closely, and an inconsistency can trigger a suspicious transaction report and account freeze.
- Real estate. Cash or third-party funded purchases, off-plan resales and broker arrangements. Real estate agents are designated non-financial businesses with AML duties, so their reports can start an inquiry.
- Procurement and government contracting. Kickbacks, conflicted consultants and inflated variations on public projects, where the Dubai Economic Security Centre, the Abu Dhabi Accountability Authority or the State Audit Institution may be involved.
- Employee embezzlement. Finance staff diverting payments, fictitious suppliers and expense fraud, usually prosecuted as breach of trust or embezzlement and often discovered at audit.
- Virtual assets. Fraudulent token offerings, unlicensed exchange activity and laundering through wallets, now addressed expressly by the 2025 AML law and supervised by VARA and the financial free zone regulators.
- Cyber-enabled fraud. Business email compromise and payment diversion, where speed of reporting to the bank and police decides whether funds can be frozen before they leave the country.
Each hotspot has its own evidence trail and its own regulator, so the response plan should be tailored rather than generic.
Cross-border white-collar crime in the UAE
Many investigations into white-collar crime in the UAE have a foreign dimension: funds routed through Dubai, a UK-listed parent with a Gulf subsidiary, or an executive who has left the country. The UAE has extensive mutual legal assistance and extradition arrangements and has strengthened international cooperation since its removal from the FATF grey list in 2024.
Group companies face overlapping laws. A UK parent may have obligations under the UK Bribery Act, including the corporate offence of failing to prevent bribery; a Singapore or Indian parent faces its own anti-corruption and money laundering regimes. Bangladesh's Anti-Corruption Commission and Saudi Arabia's Oversight and Anti-Corruption Authority (Nazaha) are active in matters involving cross-border payments. Self-reporting in one country can trigger requests in another, so disclosure strategy needs to be coordinated across all of them.
Asset recovery often crosses borders as well. Freezing orders from the DIFC Courts, recognition of foreign judgments and civil claims in the victim's home courts can work alongside a UAE criminal complaint; see foreign judgment enforcement in the UAE and sanctions and export controls for related exposure. TRW & Co coordinates with its offices in Dhaka, Singapore and London and with local counsel in other countries.
How TRW & Co helps with white-collar crime in the UAE
We advise companies, boards and individuals facing allegations or investigations, and victims seeking to recover losses. Where representation before UAE onshore courts or the DIFC/ADGM Courts is required, we work alongside locally licensed advocates and registered practitioners.
Rapid response
We help you decide in the first 48 hours whether to preserve, investigate, report or engage the authorities. We also set the communications line with banks, auditors and staff.
Internal investigations
We scope and run investigations with forensic accountants and IT specialists. The work respects labour, data protection and confidentiality constraints, and the report is structured with disclosure in mind.
Self-reporting strategy
We assess whether, when and to whom to report under UAE law and any foreign regime that applies. We also prepare the factual narrative the authorities will expect.
Individuals under investigation
We prepare executives for summonses and interviews and advise on travel bans and asset freezes. With local advocates, we coordinate applications to vary restrictions.
Victim recovery
We combine criminal complaints with civil claims, precautionary attachments and cross-border tracing. The goal is to recover money, not only to secure a conviction.
Compliance remediation
After an incident we redesign anti-bribery, AML and approval controls, and train boards and finance teams so that the same failure is less likely to recur.
Related reading: directors' duties and liability and all TRW & Co practices.
Checklist for decision-makers
- Have a written protocol for escalating fraud, bribery and laundering allegations to the board.
- Preserve data immediately: suspend deletion, image devices and secure email accounts.
- Decide early whether self-reporting is available and beneficial, in the UAE and abroad.
- Separate the investigation team from anyone implicated, and document independence.
- Prepare individuals before any police or prosecution interview, with accurate interpretation.
- Check banking, AML and regulatory notification duties that may be triggered.
- Run employment steps in parallel and lawfully, without prejudging the outcome.
- Map foreign laws that apply to the group and coordinate disclosures across countries.
- Plan civil recovery alongside any criminal complaint.
To discuss a matter in confidence, contact TRW & Co or email info@trw.co.
Frequently asked questions
01Does UAE criminal law apply inside the DIFC and ADGM?
Yes. The DIFC and ADGM have their own civil and commercial laws, courts and regulators, but criminal law is federal and applies throughout the UAE. Fraud, bribery or money laundering by a DIFC or ADGM firm is investigated by the police and Public Prosecution and tried in the onshore criminal courts. The DFSA and FSRA enforce their own rules and refer suspected crimes to the criminal authorities.
02Can a company be prosecuted for white-collar crime in the UAE?
Yes. Under the Crimes and Penalties Law a legal person is criminally liable for offences committed in its name or on its behalf by its representatives, directors or agents. The company faces fines, confiscation and other measures, while the individuals involved remain personally liable. Government bodies are excluded. Strong compliance controls and prompt action on allegations are the main practical protections.
03Is there a deferred prosecution agreement regime in the UAE?
No. There is no deferred prosecution agreement or general plea-bargaining mechanism for bribery offences. The main incentive for disclosure is the exemption from punishment for a briber or bribe-taker who reports the offence before it is discovered. For some other offences reconciliation with the victim may affect the outcome, but that depends on the specific crime and the stage of the case.
04What changed under the 2025 anti-money laundering law?
Federal Decree-Law No. 10 of 2025 replaced the 2018 law in October 2025. It lowered the knowledge threshold so that a person can be liable where they should reasonably have known funds were criminal, added tax evasion as a predicate offence, addressed laundering through virtual assets and encryption technologies, and raised penalties, often by reference to the value of the property involved. It also strengthened asset recovery and confiscation.
05Can I be stopped from leaving the UAE during an investigation?
Yes. Prosecutors can impose travel bans on suspects during an investigation, and courts can do so in some civil matters. A ban may stay in place for the life of the case. Applications to lift or vary a ban are possible, often supported by a guarantee or by showing ties to the UAE, and should be made early with the help of a locally licensed advocate.
06Should we report suspected fraud by an employee to the police?
Often yes, but sequence matters. Preserve evidence, establish the basic facts and consider civil recovery steps such as precautionary attachment before the suspect is alerted. Check whether reporting duties apply, for example suspicious transaction reporting for regulated firms. A well-prepared complaint with documents and translations is far more effective than an early complaint based on suspicion alone.
07How do UK or other foreign laws interact with a UAE investigation?
A group may face overlapping duties. A UK parent may be exposed under the UK Bribery Act, and parents in Singapore, India or Bangladesh face their own anti-corruption and money laundering laws. Disclosures to one authority can reach another through cooperation channels. Coordinate legal advice across all relevant countries before making any report, and plan how documents and witness evidence will be shared lawfully.
Sources and official materials
- Federal Decree-Law No. 10 of 2025 on AML/CFT — Current anti-money laundering law
- UAE Financial Intelligence Unit — goAML reporting and transaction suspension powers
- Dubai Police — Economic crime complaints and investigations in Dubai
- Abu Dhabi Judicial Department — Abu Dhabi prosecution and courts
- Capital Market Authority (formerly SCA) — Capital markets supervision and enforcement
- Virtual Assets Regulatory Authority — Virtual asset regulation in Dubai
- UAE Government portal — Official information on laws and justice services
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
