Anti-Money Laundering and Combatting the Financing of Terrorism (AML/CFT)
The CBUAE established a dedicated department in August 2020 to handle all Anti-Money Laundering and Combatting the Financing of Terrorism matters (AML/CFT), which the Banking Supervision Department handled previously.
The Anti-Money Laundering and Combatting the Financing of Terrorism Supervision Department (AMLD) serves three key objectives:
- examining Licensed Financial Institutions (LFIs);
- ensuring adherence to the UAE’s AML/CFT legal and regulatory framework, and
- identifying threats, vulnerabilities and emerging risks to the UAE's financial sector.
Through AMLD, the CBUAE co-ordinates closely with the UAE’s National AML/CFT Committee to implement the National Action Plan effectively.
AMLD comprises three teams with distinct mandates:
- Compliance and Examination:
- devises the annual AML/CFT risk-based supervisory plan;
- conducts supervisory examinations and issues corrective actions to LFIs; and
- recommends sanctions and disciplinary measures in cases of LFI non-adherence.
- Policy and Co-operation:
- prepares policies and guidance for supervised LFIs;
- handles information requests from local and international regulators;
- manages co-ordination with national committees and other authorities;
- liaises with domestic and international stakeholders; and
- performs outreach activities;
- Research and Risk Analysis:
- collects AML/CFT-related data from LFIs and other stakeholders;
- performs institutional and sectoral risk assessments; and
- creates risk analysis dashboards to identify LFI vulnerabilities, for consideration in the CBUAE’s compliance and examination plans.
Within the CBUAE, AMLD co-ordinates with the Examination Division of the Banking Supervision Department to exchange AML/CFT information on LFIs. AMLD also works closely with the Enforcement Division to impose penalties set by the CBUAE’s legal, regulatory and enforcement framework.
Externally, AMLD acts as the interface between the CBUAE and domestic stakeholders. Its role in facilitating co-operation to enhance LFI compliance with AML/CFT requirements often incorporates other UAE's supervisory, regulatory and law enforcement authorities, such as the UAE’s independent Financial Intelligence Unit (FIU). AMLD also works with international stakeholders to exchange information on AML/CFT best practices, and with foreign supervisors to handle AML/CFT information requests or to perform joint AML/CFT investigations.
In April 2020, the international Financial Action Task Force (FATF) issued a Mutual Evaluation Report (MER) on the UAE’s AML/CFT measures. Based on an assessment conducted in 2019, the MER analysed the UAE’s compliance with FATF 40 recommendations and the effectiveness of the UAE’s AML/CFT system, providing recommendations on strengthening the system.
The UAE’s National AML/CFT Committee (NAMLCFTC), chaired by His Excellency the Governor of the CBUAE, subsequently revised the UAE’s National Strategy in line with risks identified in the MER and the UAE’s National Risk Assessment. Compliance with MER recommendations is a key CBUAE strategic objective and focus area for 2020-2021. The enhanced UAE National Action Plan supports the National Strategy with detailed initiatives and action to implement the MER recommendations. CBUAE contributed significantly to the development of these action items, which include multiple domestic stakeholders and authorities.
Federal Decree No. (20) of 2018 is a fundamental pillar of the UAE’s AML/CFT efforts . This Decree stipulated the establishment of:
- a committee dedicated to AML/CFT objectives, under the chairmanship of the Governor of the CBUAE; and
- an independent Financial Information Unit (FIU) to receive and investigate all reports submitted by financial institutions and other corporate establishments regarding suspected illicit financial activity.
As implemented by Cabinet Decision No. (10) of 2019, Federal Decree No. (20) of 2018 has raised the effectiveness of the AML/CFT legal and institutional framework of the nation, in line with FATF requirements and recommendations.
Two Cabinet Decisions in 2020 further tightened the UAE's AML/CFT regulatory regime:
- Cabinet Decision No. (58) introduced new requirements for entities to disclose their beneficial owners, aiming to:
- enhance the transparency of UAE-registered entities; and
- develop effective, sustainable executive and regulatory mechanisms and procedures on beneficial owner data;
- Cabinet Decision No. (74) of 2020 stipulated the implementation of relevant UN Security Council Resolutions.
The CBUAE issues guidance periodically on selected topics.
The UAE Financial Intelligence Unit (FIU), an independent body under UAE law, analyses suspicious transactions and activities that may involve money laundering, terrorism financing and related criminal activities (ML/TF), on the basis of data and reports from financial institutions and designated non-financial business and professions who collaborate and share knowledge to detect and act against such activities.
If a Licensed Financial Institution suspects that a transaction, attempted transaction, activity, or funds, constitute, in whole or in part, regardless of the amount, the proceeds of a Crime, are related to a Crime, or are intended to be used in a Crime, it must report without any delay a Suspicious Transaction Report (STR), a Suspicious Activity Report (SAR) or other report types to the FIU.
o A reporting entity in the UAE should be connected to the goAML platform to submit a STR, SAR and other report types to the FIU.
o For any technical query related to the GoAML portal (including errors or troubleshooting), please contact the FIU via goAML@UAEFIU.gov.ae
o For correspondence regarding a STR/SAR or any other filed report, please use the GoAML Message Board
o For filing/business related report queries, please contact the FIU via FIUSTR@UAEFIU.gov.ae
o For any query related to the IEMS system, please contact the FIU via FIUDC@UAEFIU.gov.ae
o For any other query, the FIU can be contacted via UAEFIU@UAEFIU.gov.ae
The CBUAE, jointly with the FIU, conducts outreach and awareness-raising efforts on the importance of reporting suspicious transactions in supervised sectors.
All Licensed Financial Institutions (LFIs) must comply fully with the obligation to implement all relevant CBUAE measures without delay, as outlined in:
- Cabinet Decision No. (74) of 2020; the “Guidance on Targeted Financial Sanctions (TFS) for FIs and Designated Non-Financial Business and Professions (DNFBPs)”, issued by the Executive Office of the Committee for Goods & Material Subjected to Import and Export Control;
- CBUAE “Guidance for LFIs on the implementation of TFS”; and
- any of their amendments or updates thereof.
Appropriate TFS implementation has four key steps:
- Maintaining awareness of UNSC and UAE sanctions lists, and any related amendments.
LFIs should rely on the UNSC official website for an updated UNSC Consolidated List: Website of the UNSC
LFIs should rely on the UAE Executive Office’s official website for the most recent publication of the UAE Sanctions List (UAE Local Terrorist List), issued by the UAE Cabinet: Website of the Executive Office
In addition, LFIs must register on the Executive Office’s website in order to receive automated email notifications with updated and timely information about changes to the lists.
- Screening their databases and transactions against the lists of sanctioned persons.
- When the screening process shows a “confirmed” or a “potential” match, LFIs must immediately, without delay and without prior notice, freeze or suspend all funds or transactions.
- Reporting "confirmed" or "potential" matches and subsequent LFI actions on the UAE Financial Intelligence Unit’s (FIU) online reporting platform (goAML).
For any ‘confirmed match’ with the list of names of individuals, groups, or entities in the UAE Local Terrorist List or UNSC Consolidated List, LFIs are required to:
- Report any freezing measures on funds/services and any attempted transactions via the goAML Platform within two business days, by selecting the Fund Freeze Report (FFR); and
- Ensure prompt submission all information and documents relating to the ‘confirmed match’ with the FFR.
For any ‘potential match’ with the list of names of individuals, groups, or entities in the UAE Local Terrorist List or UNSC Consolidated List, LFIs are required to:
- Report the ‘potential match’ via the goAML Platform by selecting the Partial Name Match Report (PNMR);
- Ensure submission of all related information and documents on the potential match; and
- Uphold suspension measures on the ‘potential match’ until the LFI receives further instructions (via the goAML Platform) on whether to cancel the suspension or implement freezing measures.
The CBUAE conducts TFS outreach and awareness-raising campaigns for supervised sectors jointly with the Executive Office of the Committee for Goods and Material subjected to Import & Export Control.
A resident natural or juridical person may only carry on Hawala activity in the UAE if they hold a Hawala Provider Certificate issued by the CBUAE in accordance with its Regulations. A Registered Hawala Provider must comply fully with UAE Decree Federal Law and Executive Regulations, and any CBUAE Regulations and directions.
The CBUAE conducts outreach and awareness-raising campaigns on Registered Hawala Providers and the associated legal requirements.
The CBUAE conducts thematic reviews, outreach and awareness events for its supervised sectors. It also participates actively in events and discussions on AML/CFT issues facing the banking industry, often alongside the private sector.
The CBUAE requires all LFIs to comply with UAE Decree Federal Law and Executive Regulations, and any CBUAE Regulations and directions.
As a general principle, the CBUAE will publish the outcome of administrative and financial sanctions, including penalties imposed as result of enforcement action.
- CBUAE imposes financial sanction on an exchange house operating in the UAE (22/04/2021)
- CBUAE imposes financial and administrative sanctions on a non-authorised individual related to an exchange house (25/02/2021)
- CBUAE imposes financial sanction on an exchange house operating in the UAE (10/02/20210)
- CBUAE imposes financial sanctions on 11 banks operating in the UAE (31/01/2021)
- CBUAE imposes administrative sanctions on two exchange houses operating in the UAE (26/10/2020)
The CBUAE is focused on strengthening key partnerships with domestic and international stakeholders.
Websites of domestic supervisory authorities:
Abu Dhabi Global Market (Financial Services Regulatory Authority)
Dubai International Financial Centre (Dubai Financial Services Authority)
Securities & Commodities Authority
Ministry of Economy
Ministry of Justice
Ministry of Community Development
Websites of international organisations:
- For any query on AML/CFT supervision, please contact email@example.com
- For any technical query on the GoAML portal (including errors or troubleshooting), please contact the UAE’s Financial Intelligence Unit (FIU) via goAML@UAEFIU.gov.ae
- For any correspondence on STR/SAR or any other successfully filed report, please submit a message through the GoAML Message Board For filing/business related queries about reports, please contact the FIU via FIUSTR@UAEFIU.gov.ae
- For any IEMS-related query or request, please contact the FIU via FIUDC@UAEFIU.gov.ae
- For any other query, the FIU can be contacted via UAEFIU@UAEFIU.gov.ae
- For any query related to Targeted Financial Sanctions, please contact the Executive Office of the Committee for Goods and Materials Subject to Import and Export Control via firstname.lastname@example.org