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21 September 2020, 12:17


Eliminating ML/FT risk in the UAE

UAE Regulatory Landscape

In the past years, the UAE has made significant improvements to its AML/CFT system. The UAE has demonstrated a high-level commitment to better understand and mitigate its money laundering/terrorist financing.

The Dubai Financial Services Authority (DFSA), the Abu Dhabi Financial Services Regulatory Authority (FSRA), have developed a detailed understanding of ML/TF risk.

The Framework in the UAE (Picture)
  1. Free zones: Constitutional separation of jurisdictions for commercial laws in financial free zones.
  2. Financial free zones: DIFC Authority – commercial licensing, corporate filings and data protection. DFSA – financial services regulation .

DIFC: Established in 2004, the DIFC is home to companies of banking and financial institutions and has, since its inception, grown to become one of the top financial centers in the world.


Important Regulators:

1. UAE Securities & Commodities Authority

2. UAE Central Bank

SARs must be submitted to the DFSA:

In discharging its regulatory mandate, the DFSA has a statutory obligation to pursue the following objectives.

  • To foster and maintain fairness, transparency and efficiency in the financial services industry (namely, the financial services and related activities carried on) in the DIFC.
  • To foster and maintain confidence in the financial services industry in the DIFC.
  • To foster and maintain the financial stability of the financial services industry in the DIFC, including the reduction of systemic risk.
  • To prevent, detect and restrain conduct that causes or may cause damage to the reputation of the DIFC or the financial services industry in the DIFC, through appropriate means including the imposition of sanctions.
  • To protect direct and indirect users and prospective users of the financial services industry in the DIFC.
  • To promote public understanding of the regulation of the financial services industry in the DIFC.
  • To pursue any other objectives as the Ruler may, from time-to-time, set under DIFC Law.

Key Take Aways

The main risks faced by the UAE are at the moment a wide range from: terrorist financing, and a range of ML activities including professional third-party money laundering, cash-based money laundering, abuse of legal persons, trade-based money laundering and the laundering of proceeds, particularly from foreign predicate offences including fraud, tax offences and organised crime.

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