The Financial Markets Tribunal (FMT) has upheld a decision by the Dubai Financial Services Authority (DFSA) to impose a USD 25,000 fine on Al Ramz Capital LLC for failing to promptly report suspicious trading activity, reinforcing regulatory expectations around market conduct and compliance within the Dubai International Financial Centre (DIFC).
Background of the Case
The penalty relates to transactions executed in April 2022 on Nasdaq Dubai on behalf of a client. Under DFSA rules, firms are required to notify the regulator immediately when they have reasonable grounds to suspect that a transaction may constitute market abuse.
Following a review, the DFSA concluded that Al Ramz had reasonable grounds to suspect that certain trades may have involved potential market abuse. However, the firm did not report the transactions to the regulator as soon as the obligation arose.
As a result, the DFSA issued a Decision Notice in June 2024 imposing a financial penalty of USD 25,000 (approximately AED 91,813).
Tribunal Decision
Al Ramz Capital referred the matter to the Financial Markets Tribunal, arguing that it did not believe the transactions amounted to market abuse and therefore did not consider reporting necessary.
In its ruling issued on 3 February 2026, the Tribunal dismissed the firm’s reference and upheld the DFSA’s decision. The Tribunal emphasized that the obligation to report suspicious activity is based on an objective assessment not solely on a firm’s subjective belief.
The ruling confirmed that once reasonable grounds for suspicion exist, regulated entities must notify the regulator without delay.
Regulatory Significance
The decision underscores the DFSA’s commitment to maintaining market integrity and enforcing compliance standards among Recognised Members operating within the DIFC.
Timely reporting of suspicious transactions is a core component of market oversight. Regulators rely on such disclosures to investigate potential misconduct, prevent market distortion, and protect investor confidence.
The case serves as a reminder to financial institutions that robust internal surveillance systems and clear escalation procedures are essential to meeting regulatory obligations.
Commitment to Market Integrity
The Tribunal’s decision reinforces the principle that firms operating in regulated markets must apply objective judgment when assessing potential market abuse and act promptly when reporting thresholds are met.
For market participants, the ruling highlights the importance of compliance frameworks that ensure early detection, escalation, and reporting of suspicious activity in line with DFSA requirements.
