Ruling reinforces immediate reporting duties for suspected market abuse on DIFC markets
Dubai: The Financial Markets Tribunal has upheld a $25,000 fine imposed by the Dubai Financial Services Authority (DFSA) on Al Ramz Capital LLC for failing to promptly report suspicious transactions executed on Nasdaq Dubai.
The ruling, issued on February 3, 2026, dismissed a reference brought by Al Ramz Capital LLC against a DFSA Decision Notice dated June 13, 2024. The $25,000 penalty relates to transactions executed in April 2022 on Nasdaq Dubai on behalf of a client.
The DFSA announced the outcome on Monday, noting that the Financial Markets Tribunal had confirmed its finding that Al Ramz breached regulatory requirements by failing to report the trades as soon as there were reasonable grounds for suspicion.
Obligation to Report
The DFSA’s case focused on Al Ramz’s role as a Recognised Member of Nasdaq Dubai. Under DFSA rules, such firms must notify the regulator immediately if they have reasonable suspicion 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 in question could constitute market abuse, thereby triggering an obligation to submit a Suspicious Transaction and Order Report (STOR). The firm was found to have failed to submit the report without delay, in breach of regulatory requirements.
As a result, the DFSA imposed a fine of $25,000, equivalent to Dh91,813.
Interpretation rejected
Before the Financial Markets Tribunal, Al Ramz argued that it had not breached the relevant rule because it did not actually suspect market abuse in relation to the trades at the time they were executed.
The Tribunal rejected this argument, ruling that the obligation to report does not depend on a firm’s subjective belief. In its decision, the Tribunal stated that the correct interpretation of the rule requires an objective assessment.
“In our view, the proper construction of the REC 3.4.5 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 Tribunal said.
Based on the information available to Al Ramz at the relevant time, the Tribunal found that there were objectively reasonable grounds to suspect that the trades may have constituted market abuse.
Timely reporting key
Commenting on the decision, Alan Linning, Managing Director of Enforcement at the DFSA, said the case underlined the importance of prompt reporting by authorised firms and recognised members.
“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,” he said.
Linning said that when firms submit a STOR, they are expected to clearly explain the basis for their suspicion and provide full details, including the date and time of the transaction, the client and other 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 of DFSA-administered markets.”
Appeal window open
The Tribunal’s decision confirms the DFSA’s enforcement action, but Al Ramz retains the right to appeal. The firm has 28 days from the date of the Tribunal’s decision to lodge an appeal.
The DFSA said it remains committed to enforcing high regulatory standards across the Dubai International Financial Centre and will continue to take action where firms fail to meet their obligations.
The Decision Notice and the Financial Markets Tribunal’s ruling have been published on the DFSA’s website.
