DFSA Fines Hayman-Woodward USD 454,367 for Operating Without DNFBP Registration
The Dubai Financial Services Authority (DFSA) has fined Hayman-Woodward Global Mobility Services (DIFC) Ltd USD 454,367 (AED 1.67 million) for providing company formation and related services without the required registration.
The company served 71 clients between August 2018 and February 2025. However, its commercial licence covered only management consultancy and document clearing services.
The DFSA announced the fine on 15 October 2026.
The case highlights why UAE businesses must ensure their actual services match their licensed activities and regulatory registration.
Why Did the DFSA Fine Hayman-Woodward?
The DFSA found that Hayman-Woodward had breached Article 71A(1) of the Regulatory Law 2004.
Under this law, a business classified as a Designated Non-Financial Business or Profession (DNFBP) cannot carry out certain activities in or from the Dubai International Financial Centre (DIFC) without registering with the DFSA.
Although Hayman-Woodward held a consultancy licence, it also helped clients set up companies and provided registered office and business addresses. These services fall under the category of a company service provider (CSP).
The company also had agreements with three free zones outside the DIFC to help clients establish businesses. One of these agreements specifically described Hayman-Woodward as a DNFBP.
The DFSA did not accuse the company of money laundering. The issue was that it had provided services requiring registration without being registered.
Alan Linning, the DFSA’s Managing Director of Enforcement, explained that unregistered businesses are harder for regulators to supervise, which increases the risk of financial crime.
Which Businesses Need DNFBP Registration in DIFC?
The DFSA initially calculated a total penalty of USD 522,047.05. The company agreed to settle the case and received a 30% reduction on the fine portion.
| Penalty details | Amount (USD) |
| Original penalty | 522,047.05 |
| Settlement discount | (67,680.00) |
| Final penalty | 454,367.05 |
The total also included USD 242,800 in client fees that Hayman-Woodward earned from providing services without registration. The DFSA required the company to give up this income through a process called disgorgement.
The calculation also included eight years of unpaid registration fees, normally USD 6,000 per year, along with interest.
How Was the USD 454,367 Fine Calculated?
A DNFBP is a business or profession that is not a financial institution but must follow certain anti-money laundering rules because of the services it provides.
Under the DFSA’s rules, company service provider activities include:
- Helping clients establish companies or other legal entities.
- Acting as, or arranging for someone to act as, a company director, secretary or partner.
- Providing registered office addresses, business addresses or correspondence addresses.
- Acting as, or arranging for someone to act as, a nominee shareholder.
Hayman-Woodward was found to have carried out the first and third activities without the required registration.
DFSA Registration, goAML and Compliance Requirements
A corporate service provider in the UAE must check which registration requirements apply to its activities and location.
In the DIFC, businesses that qualify as DNFBPs must register with the DFSA and meet the relevant anti-money laundering (AML) requirements.
These include appointing a Money Laundering Reporting Officer (MLRO), checking customers’ identities, assessing business risks, and keeping proper compliance records.
DNFBPs must also register on goAML, the UAE Financial Intelligence Unit’s online system for reporting suspicious activities and transactions.
It is important to understand that goAML registration and DFSA DNFBP registration are two separate requirements. Completing one does not replace the other.
Businesses can learn more through ADEPTS’ UAE AML/CFT regulatory compliance guide and its guide to the DFSA approval process for DIFC.
How Does This Case Relate to the UAE's New AML Law?
The UAE introduced Federal Decree-Law No. 10 of 2025, which took effect on 14 October 2025 and replaced the previous anti-money laundering law.
The new law strengthens the country’s approach to preventing money laundering, terrorist financing and other financial crimes.
Businesses are expected to understand the risks associated with their customers and transactions, carry out appropriate checks and maintain records showing how they meet their legal obligations.
ADEPTS recently covered these requirements in its guide to the new UAE AML law for DNFBPs.
Although the federal AML law applies across the UAE, different authorities supervise businesses depending on where they operate.
The DFSA supervises relevant DNFBPs in the DIFC.
In Abu Dhabi Global Market (ADGM), the applicable ADGM authorities handle supervision. For most DNFBPs operating on the mainland or in non-financial free zones, supervision generally falls under the Ministry of Economy and Tourism.
Other Recent UAE Regulatory Penalties
The Hayman-Woodward case follows several other enforcement actions involving businesses operating without the required authorisation or failing to meet regulatory requirements.
- On 1 October 2026, the DFSA fined Vault Wealth USD 109,200 (approximately AED 401,000) for providing financial services without the required authorisation.
- The ADGM Registration Authority also imposed penalties totalling USD 100,000 on PKF Accountants and Business Advisers.
- In June 2023, the DFSA fined Alessandro Faro Trading Ltd USD 25,200 for carrying out activities involving precious metals and stones without DNFBP registration.
- The latest Hayman-Woodward penalty is approximately eighteen times the Alessandro Faro Trading fine, although the two cases involved different circumstances.
These actions show the importance of checking regulatory requirements before offering services.
ADEPTS has also discussed the wider enforcement environment in its article on UAE AML enforcement and AED 380 million in penalties during the first half of 2025.
Businesses can review the DFSA’s regulatory actions and its earlier announcement concerning DNFBP registration breaches for further details
What Should UAE Company Service Providers Do?
The case offers three important lessons for company formation agents, business setup consultants and other corporate service providers in the UAE.
- Check your business activities. Review the services your company actually provides and compare them with your commercial licence. Activities such as DIFC company formation, registered address services and nominee arrangements may require additional registration. ADEPTS’ legal structuring services can assist with reviewing business structures and related requirements.
- Review your business agreements. Check agreements with free zones, referral partners and customers. These documents may show that your company is providing services that require DNFBP registration.
- Keep your AML compliance up to date. Complete the required registrations, including DFSA and goAML registration where applicable. Appoint an MLRO, verify customer information, assess risks and maintain records of compliance activities. Businesses planning to operate in the DIFC can also explore ADEPTS’ DIFC free zone business setup services.
How Can ADEPTS Help With DNFBP Registration and AML Compliance?
ADEPTS Chartered Accountants helps UAE businesses identify their DNFBP registration requirements and meet their AML compliance obligations.
Through its AML and compliance services in the UAE, ADEPTS supports businesses with registration assessments, AML policies, customer verification procedures, risk assessments, and compliance documentation.
ADEPTS also provides corporate governance services to help businesses strengthen internal controls and maintain proper compliance oversight.
Conclusion
The DFSA’s USD 454,367 fine against Hayman-Woodward shows that having a commercial licence is not always enough to provide certain business services legally.
Companies involved in business setup, registered address services and other corporate activities should check whether DNFBP registration applies to them and ensure their AML procedures meet the relevant requirements.
Businesses seeking guidance can contact ADEPTS Risk Advisory for support with DNFBP registration assessments and AML compliance.
References
- 71A DNFBP Prohibition | Rulebook. https://dfsaen.thomsonreuters.com/rulebook/71a-dnfbp-prohibition
- Decision Notices & Regulatory Actions. https://www.dfsa.ae/what-we-do/enforcement/regulatory-actions .
- DFSA Takes Action against Two Firms for Regulatory Breaches. https://www.dfsa.ae/news/dfsa-takes-action-against-two-firms-regulatory-breaches.
- Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing. https://uaelegislation.gov.ae/en/legislations/3314/download.
- The DFSA Fines HAYMAN-WOODWARD GLOBAL MOBILITY SERVICES (DIFC) LTD. USD 454,367 for Breaching the DNFBP Prohibition. https://www.dfsa.ae/news/hayman-woodward-global-mobility-services-difc-ltd.
- The DFSA Is the Independent Regulator of Financial Services. https://www.dfsa.ae/.
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