Financial Markets Tribunal upholds DFSA fine on Al Ramz for late suspicious-transaction reporting
Recognised Members must file STORs when objective suspicion exists
Change
Financial Markets Tribunal upheld DFSA’s USD 25,000 fine on Al Ramz Capital LLC for failing to immediately report suspicious transactions executed on Nasdaq Dubai.
Why it matters
The tribunal confirmed that the reporting duty turns on objective reasonable grounds to suspect market abuse, not whether the firm actually suspected it. Recognised Members and Authorised Firms must submit Suspicious Transaction and Order Reports immediately when client orders or transactions meet that threshold.
Implications
- — Recognised Members of Nasdaq Dubai must file Suspicious Transaction and Order Reports immediately when objective reasonable grounds for market-abuse suspicion exist because the tribunal rejected reliance on the firm’s subjective view.
- — Authorised Firms handling exchange or OTC transactions must document the date, time, client, parties involved and investment details in STOR submissions because DFSA said those details are required to support market-abuse detection.
- — Market-abuse surveillance teams must escalate suspicious orders against an objective-reasonable-grounds threshold because DFSA’s fine was upheld despite Al Ramz arguing that it did not actually suspect market abuse.
Who is affected
- — Recognised Members of Nasdaq Dubai
- — DFSA Authorised Firms handling client orders or transactions
- — Market-abuse surveillance and STOR escalation teams in DIFC
What to watch
- — Financial Markets Tribunal decision date: 3 February 2026
- — Appeal window: 28 days from the tribunal decision