In the UAE, depositing money into bank accounts of unknown or unidentified individuals is considered a behaviour that may lead to legal accountability, especially if the recipient account is later found to be linked to organised crimes such as money laundering, terrorist financing, or drug trafficking. Several cases have occurred where individuals were prevented from making bank transfers due to suspicions about the nature of the recipient accounts. Investigations revealed that some depositors acted on requests from strangers without realising the severity of their actions.
Lawyer Badr Abdullah Khamees emphasised that anyone transferring or depositing money must verify its source, its legality, the recipient, and the purpose of the transaction. He warned that transferring money to unknown individuals, especially via ATMs under the pretext of them not having ID cards, is a risky behaviour.
The person using their identity for such deposits bears legal responsibility, even if they are unaware of the beneficiary.
The funds could be part of drug trafficking, terrorist financing, or other crimes. Khamees affirmed that article (2) of the Anti-Money Laundering and Counter-Terrorist Financing Law states that anyone who transfers, moves, or uses funds knowing they are proceeds of crime, with the intent to conceal or disguise their origin, is committing a money laundering offense. Khamees added that Article 22 of the law imposes penalties of 1 to 10 years’ imprisonment and a fine ranging from Dhs100,000 to Dhs5 million, or either of these penalties.
Legal Consultant Dr. Ali Musbeh stressed that even unintentional assistance in depositing funds can place the individual under legal scrutiny, regardless of their intent.
Dr Musbeh highlighted that Federal Law No. 20 of 2018 confirms that merely moving or depositing funds from an illicit source, with knowledge of their origin, constitutes a money laundering crime and courts have previously convicted individuals who transferred funds at the request of friends or acquaintances without questioning the source or purpose, only to discover the accounts were linked to money laundering networks. Legal Consultant Mohammed Hussein noted that this phenomenon is on the rise, with some individuals exploiting others’ sympathy outside exchange offices, claiming they cannot deposit the money themselves.
He warned that simply depositing funds into a suspicious account, even without prior knowledge, could lead to accusation and potential punishment unless the individual can prove they were a victim of fraud or had no malicious intent.