Dubai, United Arab Emirates, The Dubai Financial Services Authority (DFSA), the independent banking, financial services, and markets regulator of Dubai International Financial Centre (DIFC), has been awarded approximately USD 143,000 (AED 524,810) towards its external and internal legal costs by the Financial Markets Tribunal (FMT) following a reference by Al Ramz Capital LLC (Al Ramz) of a DFSA Decision Notice dated 13 June 2024. This is the first case in which the DFSA has sought recovery of its internal legal costs in proceedings before the FMT, with all internal costs relating to Al Ramz’s privacy application and 25% of the internal costs claimed for the substantive reference being awarded.

It also reflects the extent to which the FMT accepted the DFSA’s submissions that Al Ramz had acted unreasonably in certain aspects of the reference. These included not narrowing the issues at an earlier stage, pursuing factual arguments that had little prospect of success, and raising an argument about subjectivity in suspecting market abuse at a very late stage in the reference rather than during the earlier DFSA Decision Maker process.

Alan Linning, Managing Director, Enforcement, of the DFSA, commented: “The DFSA fully supports the right of firms and individuals to challenge its enforcement decisions and to apply for privacy where appropriate. However, this decision makes clear that where a party pursues arguments unreasonably, or advances arguments it should know have no merit, it may be required to contribute to the DFSA’s costs in addition to paying any financial penalty imposed.”

The FMT upheld the DFSA’s decision to impose a USD 25,000 (AED 91,750) fine on Al Ramz on 3 February 2026. On 24 June 2026, the FMT ordered Al Ramz to pay close to AED 525,000 (approximately USD 143,000) towards the DFSA’s legal costs, which comprise its external legal costs, all internal costs relating to Al Ramz’s privacy application, and 25% of the internal costs claimed for the substantive reference. 

In its costs decision, the FMT stated:

“[a] party should normally expect to be awarded their external legal costs when they are clearly the successful party on all the issues that arise in the reference.”

In awarding the DFSA its full external and internal legal costs in respect of Al Ramz’s application for the reference to be dealt with in private and the Decision Notice not to be published prior to the hearing of the reference, the FMT said:

“[t]he Tribunal held that in essence, the Applicant’s [Al Ramz’s] concerns amounted to fears about the effect of publication on the Applicant’s reputation accompanied by a considerable amount of speculation on its part…

In our view, it should have been clear to the Applicant, who had the benefit of advice of experienced Counsel on the matter, that its submissions on privacy were bound to fail. It follows that it was unreasonable of the Applicant to make the Privacy Application on the basis that it did.”

The decision reinforces the DFSA’s ability to defend its enforcement decisions effectively and to seek recovery of legal costs where a reference is pursued unreasonably. The DFSA remains committed to taking fair, proportionate, and robust enforcement action to uphold the integrity of financial services in DIFC.

The DFSA's Decision Notice is accessible in the Regulatory Actions section of the DFSA website. The FMT’s costs decision and substantive decision in the reference are available in the FMT section of the DFSA website. ​​​​​Al Ramz has 28 days after the date of the FMT’s costs decision to appeal the decision on a point of law only.

The Dubai Financial Services Authority (DFSA) is the independent regulator of financial services conducted in and from the Dubai International Financial Centre (DIFC), a purpose built financial free zone in Dubai. The DFSA's regulatory mandate covers asset management, banking and credit services, securities, collective investment funds, custody and trust services, commodities futures trading, Islamic finance, insurance, crowdfunding platforms, money services, an international equities exchange and an international commodities derivatives exchange. In addition to regulating financial and ancillary services, the DFSA is responsible for administering Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) legislation that applies to regulated firms and Designated Non-Financial Businesses and Professions in DIFC. Please refer to the DFSA’s website for more information.

Alan Linning joined the Dubai Financial Services Authority (DFSA) in July 2025 as Managing Director, Enforcement. He brings over three decades of extensive legal, regulatory, and enforcement experience to the DFSA, having worked across a broad spectrum of complex financial regulation, enforcement action, and compliance matters within global financial markets. Prior to joining the DFSA, Mr Linning held various senior positions within top-tier regulatory bodies and law firms, where he held high-profile investigations and contributed to shaping policy and strategy in financial enforcement. He was most recently a Partner in Litigation and Dispute Resolution at Mayer Brown in Hong Kong. Previously, he spent eight years as Partner, Head of Disputes and Regulatory at Sidley Austin, and was Executive Director of Enforcement at Hong Kong’s Securities and Futures Commission. Mr Linning holds a Law degree from the University of Edinburgh.