At present, whistle-blower protection is not expressly adopted in UAE Federal Laws, although this may be an area for legislative development given the critical role whistleblowing can play in eliminating bribery, corruption and money-laundering practices. There are, however, protections at an Emirate level and in specific free-zones.
Under Dubai Law No. 4 of 2016 on Financial Crimes (the “Law on Financial Crimes”), whistle-blower protection may apply if the information disclosed is true, relates to an activity that may affect the economic security of Dubai, and has been disclosed to the Dubai Centre for Economic Security (the "DESC").
In these cases, the divulgence of such information shall not be treated as a violation. Pursuant to Article 19 of the Law on Financial Crimes, the DESC shall provide the necessary protections for the informer, which includes protection at his/her place of residence and workplace, and not disclosing any information related to the informer’s identity or whereabouts.
In April 2022, in the Dubai International Financial Centre (the “DIFC”) the Dubai Financial Services Authority (the “DFSA”) published its Whistleblowing Regime. This requires a DIFC-registered auditor, a DFSA Authorised Person (being an entity licensed to undertake financial services in the DIFC) or a Designated Non-Financial Business or Profession (including real estate developers, dealers in precious metals, law firms, accounting firms, company service providers or a single family office) to establish procedures for the reporting of regulatory concerns. Amendments to the DIFC Regulatory Law 2004 have provided protections to whistle-blowers when the good faith disclosure relates to a reasonable suspicion that the organisation has contravened any law or is engaged in a financial crime.
On 31 May 2025, the ADGM’s Whistleblower Protections Regulations came into effect. The Regulations apply to all ADGM entities and require them to implement “appropriate and effective arrangements” to facilitate the making of a report and to protect the whistleblower’s identity. The Regulations do not prescribe precisely what arrangements should be implemented and/or how but require them to be “proportionate to the size and complexity of its business and operations” and, in most cases, set out in written policies and procedures. As a matter of practically, ADGM entities should ensure that they implement and maintain a clear and concise whistleblowing policy, which emphasises confidentiality for reports and non-retaliation for reporting. Such policy should be well-communicated throughout the business, so it may need to be disseminated in several languages (for example, Arabic and English), and for larger entities, training on the policy may be appropriate.
Similarly, Article 284 of the Penal Code appears to provide complete protection for bribery offences if the whistle-blower makes a report to the relevant judicial or administrative authorities before the crime is discovered.