Mirabaud (Middle East) Limited (MMEL), a part of the Switzerland-based Mirabaud Group, has been fined US$2.04 million by the Dubai Financial Services Authority (DFSA). This penalty was imposed for inadequate anti-money laundering systems and controls.

The DFSA took action against MMEL, citing multiple compliance failures during the Relevant Period (June 2018 to October 2021). Key deficiencies include inadequate AML/CFT systems, an inability to identify CDD inconsistencies, overlooking account purposes during transactions, failure to detect suspicious transactions, non-compliance with high-risk customer and PEP policies, and insufficient evidence of customers’ prior trading experience.

During the assessment, it was found that a group of nine interconnected client accounts managed by the same Relationship Manager raised several red flags related to suspicions of money laundering. The activities of the relevant customer accounts exhibited characteristics commonly seen in the layering phase of a money laundering operation, including:

• The opening and operation of seemingly unconnected entities by a small group of closely connected individuals.
• Deposits of funds from third-party accounts.
• Overly complex transactions inconsistent with the nature of the accounts and the information known about the customers.
• Significant funds transferred overseas to third-party entities with opaque ownership structures and bank accounts in jurisdictions different from those in which they were based.
• Repeated funds flowing between connected entities.