Financial Crime Controls in the UAE

The Central Bank of the UAE has issued updated guidance on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing (AML/ CFT / CPF) for Licensed Financial Institutions and Registered Hawala Providers. The guidance is aligned with international best practices, the UAE National Strategy 2024–2027, and FATF expectations.

For years, the UAE has sometimes been perceived by parts of the international market as a convenient jurisdiction for hiding income, moving questionable funds, or conducting opaque financial operations. Whether fairly or unfairly, such perceptions matter because trust is a strategic asset for any global financial hub.

Photo: jcomp na Magnific  www.magnific.com/pl 

The latest CBUAE actions show a clear direction: stronger controls, higher expectations, and more structured supervision of financial crimerisks.

The updated package covers several key risk areas:

• Proliferation Financing

Institutions are expected to assess inherent PF risks, evaluate policies and controls, remediate weaknesses, and continuously monitor emerging typologies and parties involved in potential PF activity.

• Trade-Based Money Laundering

The guidance addresses risks hidden in complex trade flows.

• Correspondent banking relationships

The guidance clarifies expectations for managing AML/CFT/CPF risks linked to correspondent banking and requires stronger monitoring of these relationships.

• CDD, KYC and record keeping

CBUAE reinforces the need to verify customer identity, assess ML/TF/PF exposure from onboarding throughout the relationship, apply simplified or enhanced due diligence where appropriate, and retain relevant records.

The package also includes best-practice manuals on implementing a risk-based approach, conducting institutional risk assessments, and designing role-based AML/CFT/CPF training for employees and senior management.

Regulators increasingly expect institutions to prove that AML/CFT/CPF controls work in practice. That means:

• proper customer risk profiling,

• ongoing monitoring,

• risk-based due diligence,

• effective escalation and suspicious activity detection,

• documented institutional risk assessments,

• clear ownership,

• trained staff,

• and controls proportionate to actual exposure.

I see this as a positive development. The more the UAE strengthens financial crime controls, the less it will be perceived as a place for questionable financial activity, and the more it will be seen simply as a strong, modern, and trusted place to do business.

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Author: Sebastian Burgemejster