UAE Trends and Developments Contributed by: Stuart Paterson, Janine Mallis, Tania Forichon and Elif Eren Ozenir, Herbert Smith Freehills Kramer LLP
mation or solicit funds. Major brands like Emirates and the Al Futtaim Group have issued guidance to help applicants identify legitimate listings. The fraudulent posts are often generated by bots capable of flood - ing job boards and social platforms, even conducting interviews with jobseekers via online chats using AI- generated recruiter profiles. While there is no specific AI law in the UAE, particu - larly one designed to deal with these emerging threats, the existing criminal law framework is likely to be able to ensure that fraudsters are held accountable and appropriately sanctioned (regardless of whether they use AI). For instance, fraud is treated as a criminal offence under the UAE Penal Code (Federal Decree Law No 31 of 2021, as amended) and cyberfraud is criminalised by multiple offences under the Cyber Crimes Law. It remains to be seen whether the UAE courts will impose even harsher penalties in cases where offenders have exploited advanced technolo - gies to perpetrate their crimes, but the legislative tools are already in place to prosecute such conduct effec - tively. ADGM Raises the Bar on Whistle-Blower Protections In a significant step towards fostering transparency and accountability, the Abu Dhabi Global Market (ADGM) introduced the Whistleblower Protection Regulations 2024. While the regime came into force in July 2024, ADGM entities had until 31 May 2025 to comply. Supplementary guidance issued in July 2025 provides practical direction, though it remains non-binding. The framework offers robust protection for individuals making good-faith disclosures of sus - pected breaches of ADGM laws, financial crime, or misconduct. Only disclosures which meet the require - ment of a “Protected Disclosure” will be offered the protections as set out in the ADGM Regulations. The disclosures must be: • information related to knowledge or reasonable suspicion; • that a contravention of ADGM rules or regulations, or money laundering, fraud or any other financial crime occurred; • made in good faith; and • through an internal or external reporting channel.
Protected Disclosures can be made anonymously – however, the ADGM’s guidance cautions that doing so can present challenges, as it may hinder the effective - ness of any subsequent investigation. Entities operating in the ADGM must now maintain proportionate whistle-blowing arrangements, includ - ing clear reporting channels, confidentiality safe - guards, and anti-retaliation measures. Larger entities and Designated Non-Financial Businesses or Profes - sions are subject to even more stringent policy require - ments. Importantly, the ADGM Registration Authority has enforcement powers, including financial penalties and licence suspension. With the compliance dead - line now passed, attention turns to how rigorously the Financial Services Regulatory Authority and Registrar will enforce the new regime – and whether ADGM enti - ties will rise to the challenge of embedding a genuine “speak-up” culture. UAE’s Removal From EU AML High-Risk List On 9 July 2025, the European Parliament approved the European Commission’s decision to remove the UAE from its list of high-risk third countries with stra - tegic deficiencies in anti-money laundering (AML) and combating the financing of terrorism (CFT) frame - works. This follows the UAE’s exit from the Financial Action Task Force (FATF) grey list in February 2024 and reflects the EU’s broader objective of aligning its list with internationally recognised standards. Until now, EU-based “obliged entities”, including banks, auditors and legal professionals, were required to apply enhanced due diligence when dealing with UAE clients, often resulting in delays and increased compli - ance burdens. While the European Commission’s decision was ultimately upheld, it faced some resistance in the European Parliament. A motion for a resolution was introduced, arguing that the delisting was premature and citing concerns over the effectiveness of recent reforms and ongoing risks in financial free zones. However, the motion was unsuccessful, and the final vote signalled growing confidence in the UAE’s efforts to combat financial crime. The UAE welcomed the decision as independent recognition of its commitment to international stand -
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