Dubai tribunal upholds DFSA fine against Al Ramz Capital over delayed reporting of suspicious trades

The Financial Markets Tribunal has upheld a decision by the Dubai Financial Services Authority (DFSA) to fine Al Ramz Capital LLC $25,000 for failing to promptly report suspicious transactions executed on Nasdaq Dubai.

In a ruling issued on February 3, 2026, the Tribunal dismissed a reference brought by Al Ramz Capital against a DFSA Decision Notice dated June 13, 2024. The enforcement action relates to trades carried out in April 2022 on Nasdaq Dubai on behalf of a client.

The DFSA confirmed the outcome on Monday, stating that the Tribunal had upheld its finding that Al Ramz breached regulatory requirements by not reporting the transactions as soon as reasonable grounds for suspicion arose.

Obligation to report
The DFSA’s case focused on Al Ramz’s role as a recognized member of Nasdaq Dubai. Under DFSA rules, such firms are required to notify the regulator immediately if they reasonably suspect that a client’s order or transaction may constitute market abuse, including market manipulation.

The Authority concluded that Al Ramz had reasonable grounds to suspect the transactions may have involved market abuse, triggering an obligation to submit a Suspicious Transaction and Order Report (STOR). It found that the firm failed to submit the report without delay and imposed a fine of $25,000, equivalent to Dh91,813.

Tribunal rejects interpretation
Before the Financial Markets Tribunal, Al Ramz argued that it had not breached the relevant rule because it did not subjectively suspect market abuse at the time the trades were executed.

The Tribunal rejected this argument, ruling that the obligation to report is based on an objective standard rather than a firm’s internal belief. In its decision, the Tribunal stated that the duty to notify the DFSA arises where there are reasonable grounds for suspecting market abuse in an objective sense, regardless of whether the firm actually suspected wrongdoing at the time.

Based on the information available to Al Ramz at the relevant time, the Tribunal found that there were objectively reasonable grounds to suspect the trades may have constituted market abuse.

Timely reporting was emphasized.
Commenting on the ruling, Alan Linning, Managing Director of Enforcement at the DFSA, said the decision highlighted the importance of prompt reporting by authorized firms and recognized members.

“This case is a firm reminder to authorized firms and recognized members that they must notify the DFSA immediately if they reasonably suspect that a client’s order or transaction may constitute market abuse under the Markets Law, including market manipulation,” he said.

Linning added that STOR submissions should clearly explain the basis for suspicion and include full details such as the date and time of the transaction, the parties involved, and the nature of the investment, whether on-exchange or over-the-counter.

“These reports are vital in assisting the DFSA in detecting and preventing market abuse,” he said. “They are fundamental to maintaining market integrity and protecting investors and potential participants in DFSA-administered markets.”

Appeal window open
While the Tribunal’s ruling confirms the DFSA’s enforcement action, Al Ramz Capital retains the right to appeal. The firm has 28 days from the date of the decision to lodge an appeal.

The DFSA said it remains committed to maintaining high regulatory standards within the Dubai International Financial Centre and will continue to take action against firms that fail to meet their obligations. The Decision Notice and the Tribunal’s ruling have been published on the DFSA’s website.