Where a manager employed by a legal person is found to have committed a money...

The UAE AML framework distinguishes between criminal penalties imposed on natural persons and financial liability imposed on legal persons. Under the CISI UAE Financial Rules and Regulations treatment of Federal Law No. 20 of 2018, where representatives, managers or agents of a legal person commit money laundering, financing of terrorism or financing of illegal organisations for the legal person's account or in its name, the legal person may be fined. The prescribed fine is not less than AED 500,000 and not more than AED 50 million . The question asks only for the minimum amount, which is therefore AED 500,000. The liability is expressed as a statutory monetary range, not as 1% or 2% of annual turnover. AED 250,000 is also below the minimum prescribed for the legal person in this circumstance. Separate penalties can apply directly to the natural person who actually committed the underlying offence, but that does not change the minimum fine applicable to the legal entity itself. Accordingly, option D is correct.

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