The UAE is seeking to enhance its anti-money laundering (AML) enforcement efforts

The UAE has demonstrated a strong dedication to implementing stringent regulations within the financial sector, with a primary focus on combating financial crime through a coordinated and effective approach. In recent years, significant progress has been made through the enactment of a comprehensive Anti-Money Laundering (AML) legislation and the completion of a National Risk Assessment.

These measures are not only paving the way for a more secure financial environment, but they are also reinforcing the UAE's standing as a leader in financial integrity.

Following the removal of the UAE from the Financial Action Task Force (FATF)’s grey list – of jurisdictions with strategic inadequacy related to the prevention of money laundering and terrorist financing –, on 23 February 2024, after its introduction in 2022, the UAE seeks to secure its position as a permanent member of the FATF. The independent inter-governmental body is known for its role in establishing global standards and promoting a range of policies to protect the global financial system.

Specifically, to combat money laundering, terrorist financing, and proliferation financing, which includes all the threats that could undermine the integrity and stability of the global financial system.

The next Mutual Evaluation Report (MER) of the FATF is expected to begin in 2026.

The UAE, according to the statements of Hamid Al Zaabi, Director-General of the Executive Office for Anti-Money Laundering and Counter Terrorism Financing (AML/CFT), plays a leading role on the global stage in combating financial crimes. The relevance of the country’s position is underscored by its efforts to collaborate with foreign regulators as well.

Correspondingly, as His Highness Sheikh Abdullah bin Zayed Al Nahyan, Chairman of the Higher Committee Overseeing the National Strategy on AML/CFT, stated, “The UAE’s proactive approach not only safeguards the integrity of the global financial system but also strengthens our position as a leading international financial center and trade hub”.

Let us now consider some of the most pivotal measures adopted by the UAE.

In the year 2024, the UAE has continued to pursue comprehensive reforms and initiatives designed to enhance compliance with international financial crime regulations. The introduction of strong whistleblower protection laws, that came into force on 5 July 2024, stands out in this context as it appears to be crucial for fostering a culture of transparency and accountability within the financial environment. It encourages individuals to report misconduct thanks to the newly-introduced non-retaliation protection, as disclosures can be anonymous.

In August 2024, the UAE Federal Law on anti-money laundering was amended to strengthen compliance mechanisms and encourage collaborations between businesses and regulatory authorities. In the same month, it was announced that thirtytwo gold refineries were suspended between July and October 2024 as they were found responsible for a total of 256 infractions of the AML legislation on precious metals and gemstones.

Then, in September 2024, the “National Strategy” for Anti Money Laundering, Countering Terrorism Financing and Proliferation Financing (CTF&PF) for 2024-2027 was approved by the General Secretariat of the National Committee to guarantee alignment with international standards, particularlyfollowing the methodology appointed by the World Bank. The previous initiatives in this sector have been vital for the development of the National Strategy.

Its framework consists of eleven strategic goals anchored in three core values, risk-based compliance, effectiveness and sustainability of national framework. Key objectives include enhancing national andinternational coordination to facilitate and promote financial information exchange and foster collaborative efforts; disrupting unlawful financial transactions; refining the legal tools to tackle emerging risks during an economic downturn, particularly those associated with virtual assets and the ever-evolving cybercrime techniques. The UAE has placed significant emphasis on the regulation of virtual assets, addressing this increasingly pressing priority with guidelines for licensing virtual asset service providers and ensuring consumer protection, all while promoting innovation in the financial technology sector. To achieve this extensive cooperation on the regulation of Virtual Assets, the Securities and Commodities Authority (SCA), in September 2024, signed an agreement with the Virtual Assets Regulatory Authority (VARA).

Predictably, the National Strategy will be subject of other amendments, given the upcoming 2026 FATF assessment.

Furthermore, the persisting interest of the UAE in AML enforcement strategies and CTF sanction regime will be a sign of consistency, signalling an authentic interest of the UAE in achieving a more stable financial system, worthy of public trust.

Since the beginning of January 2025, the SCA has imposed considerable financial penalties amounting to a total of AED 1.15 million against companies found to be non-compliant with anti-money laundering (AML) and counter-terrorism financing (CFT) directions.

In this regard, the CEO of the SCA, H.E. Waleed Saeed Al Awadhi, stated: "These measures are crucial for protecting investors while maintaining the integrity of financial markets in the country."

As a consequence of this progress and of a more robust compliance culture, in terms of regulatorsupervisions and AML enforcement practices, the strategic and financial vulnerabilities traditionally associated with high-risk sectors are no longer as pronounced.

The scenario in which industries such as trade, investment and real estate operate has undergone major changes. These sectors may have previously drawn considerable business activity, but the more regulated financial environment, the overall resilience and the enhanced scrutiny and rigorous enforcement measures have diminished the appeal of these sectors for the pursuit of illicit activities.

A framework that promotes equitable and licit practices significantly enhances the overall stability and security of various industries within the marketplace. This, in turn, creates a more stable and secure environment for investors while promoting a healthier economic environment, leading to sustained evolution and innovation across multiple sectors.

CC: Flavia Gabrielli