The Dubai Financial Services Authority (DFSA), the independent banking, financial services, and markets regulator of the Dubai International Financial Centre (DIFC) has today announced that the Financial Markets Tribunal has dismissed a reference by Al Ramz Capital LLC (Al Ramz) of a DFSA Decision Notice dated 13 June 2024.
On 3 February 2026, the Financial Markets Tribunal upheld the DFSA’s decision to impose a USD 25,000 (AED 91,813) fine on Al Ramz for its failure to immediately report suspicious transactions that it had executed on Nasdaq Dubai on behalf of a Client in April 2022.
Alan Linning, Managing Director of Enforcement at the DFSA, said: “This case is a firm reminder to Authorised Firms and Recognised 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.
When a firm submits a notification by way of a Suspicious Transaction and Order Report (STOR), it should explain to the DFSA its reasons for suspecting that the order or transaction may constitute Market Abuse, and provide full details including the date, time, the name of the client and other parties involved and the nature of the investment (e.g. on-exchange or over-the-counter (OTC).
These reports are vital in assisting the DFSA in detecting and preventing Market Abuse. As a result, they are fundamental to maintaining market integrity and protecting investors and potential participants of DFSA administered markets. The DFSA will continue to hold Authorised Firms and Recognised Members to the high standards expected of them. We will not hesitate to take action where those high standards are not met.”
The DFSA’s case was that as a Recognised Member of Nasdaq Dubai, Al Ramz had reasonable grounds to suspect that the transactions in question may have constituted Market Abuse. In terms of the relevant DFSA rule, Al Ramz was therefore obliged to make a report to the DFSA immediately, but failed to do so.
Before the Financial Markets Tribunal, Al Ramz argued unsuccessfully that it had not breached the Rule because it did not actually suspect Market Abuse in relation to the transactions in question.
In its decision, the Financial Markets Tribunal rejected Al Ramz’s interpretation of the Rule stating:
“In our view, the proper construction of the REC 3.4.5 [the relevant rule] leads to the conclusion that the obligation to notify the DFSA of potential Market Abuse arises where there are reasonable grounds for suspecting Market Abuse in a purely objective sense irrespective of whether the Recognised Member actually suspects Market Abuse.”
The Financial Markets Tribunal confirmed the DFSA’s decision that on the information known to Al Ramz at the relevant time, there existed, objectively, reasonable grounds to suspect the trades may constitute Market Abuse. On this basis, the Financial Markets Tribunal upheld the DFSA’s decision to impose the USD 25,000 fine on Al Ramz.
The DFSA remains committed to developing, administering, and enforcing world-class regulations of financial services within the DIFC. As part of its strategy and ongoing mission, the Authority will continue to implement stringent enforcement measures and provide clear regulatory guidance to ensure that all entities operating within the Centre adhere to the highest standards of regulation and ethical conduct.
The DFSA's Decision Notice is accessible in the Regulatory Actions section of the DFSA website. Al Ramz Capital LLC (Al Ramz) has 28 days after the date of the Financial Markets Tribunal’s decision to appeal the decision. The Financial Markets Tribunal’s decision is available in the FMT section of the DFSA’s website.
