Since April 2020, when the Financial Action Task Force reported that the United Arab Emirates (UAE) was failing to do enough to combat money laundering, the UAE has embarked on a series of actions that indicate the seriousness of its commitment to dealing with money laundering. In November 2020, the UAE announced the development of a strategic plan to support efforts to combat money laundering, established an Anti-Money Laundering Department within the Ministry of Economy, set up a series of special federal courts across the UAE to address the issue of money laundering, temporarily suspended 100 law firms in the UAE from practicing, and fined seven other law firms AED 100,000 ($27,229) each for anti-money laundering violations.
Soon thereafter, in December 2020, the UAE Cabinet approved the creation of the Executive Office of the Anti-Money Laundering and Countering the Financing of Terrorism (Executive Office). That office is established to track the UAE’s performance with reference to international anti-money laundering (AML) requirements, and to ensure the UAE’s active collaboration with companies and partners across the world.
Three recent developments in the UAE indicates that the UAE continues to demonstrate its commitment to its AML obligations. First, on March 17, Gulf Business reported that the Anti-Money Laundering and Tax Evasion Court within the Abu Dhabi Judicial Department (ADJD) convicted four individuals, all Filipino nationals, and a UAE jewelry company of committing money laundering and fraud against 4,000 people. The court sentenced each of the individual defendants to five years’ imprisonment, deportation, and a fine of AED 10 million ($2.7 million), and fined the jewelry company AED 50 million ($13.6 million). In addition, the court ordered the confiscation from the company of approximately 7,430 grams of 18 Karat gold, worth more than AED 1.37 million ($372,900).
According to the official UAE news agency WAM, the four individuals conducted an Internet fraud and pyramid scheme, in which they established a website labeled “Gold Empire Management” and used advertisements, videos, and contests posted on the site and social media to attract prospective investors in their company. The defendants charged each would-be investor a fee of AED 2,000 ($544), but reportedly encouraged victims to persuade others to participate in the spurious investment and offered them AED 1,000 ($272) for each new investor they brought in.
Second, on March 17, the UAE Financial Intelligence Unit (FIU) and the Israeli Money Laundering and Terror Financing Prohibition Authority signed a Memorandum of Understanding to promote the exchange of financial intelligence between the two agencies and strengthen the cooperation between those agencies, the UAE, and Israel to improve the joint activity against money laundering and terrorism financing.
Third, on March 24, the Executive Office announced a number of new AML measures and tools, including new restrictions on the movement of cash and precious metals. Those measures and tools include:
- (1) a “goAML: tool to submit and analyze suspicious banking reports for authorities to take legal action;
- (2) an “IEMS” platform to exchange messages between the UAE FIU, the private sector, and law enforcement entities in the UAE;
- (3) a “Fawri Tech” program to facilitate immediate action on financial issues that relate to combating the proliferation of weapons of mass destruction;
- (4) a unified e-customs platform that is directed, in the long term to controlling illicit trafficking and smuggling operations in the UAE; and
- (5) a “Declare” program to restrict the movement of cash, precious stones, and metals before and after their arrival in the UAE in connection with the movement of passengers across customs borders.
The Executive Office stated that through the adoption of these technical controls, it “hopes to strengthen the UAE’s efforts to curb illicit flows of funds, promote asset recovery, and combat all forms of transnational financial crime.”
Dipping Through Geometries 