On 2 September 2024, the UAE Cabinet approved the country’s new National Strategy for Anti-Money Laundering, Combating the Financing of Terrorism, and Countering the Financing of Proliferation (AML/CFT/CPF) for 2024–2027.
The strategy is based on the World Bank Group’s National Risk Assessment methodology and is overseen by the Supreme Committee for AML/CFT, chaired by the UAE Minister of Foreign Affairs. Its implementation is supported by the Executive Office of Anti-Money Laundering and Counter Terrorism Financing (EO AML/CTF).
This marks an important step in the UAE’s ongoing efforts to strengthen its financial system and build on the progress that led to its removal from the FATF grey list earlier in 2024.
11 Strategic Goals
The strategy sets out 11 key goals, grouped under three main pillars:
Pillar 1: Risk-Based Compliance, Effectiveness, and Sustainability
- Enhanced Risk Understanding: Regularly update the National Risk Assessment to reflect evolving threats.
- Risk-Based Supervision: Strengthen regulatory oversight of financial institutions and DNFBPs, including real estate, precious metals dealers, lawyers, auditors, and corporate service providers.
- Improved Compliance Culture: Promote awareness, training, and governance across public and private sectors.
- Resource Optimization: Ensure regulators and businesses have the right expertise and tools to apply risk-based measures effectively.
Pillar 2: National & International Cooperation
- Cross-Government Collaboration: Improve coordination among the Central Bank, SCA, Ministry of Economy, law enforcement, customs, and the judiciary.
- International Cooperation: Expand partnerships with organizations such as the FATF and Egmont Group for intelligence sharing, joint investigations, and exchange of best practices.
- Sanctions Implementation: Reinforce compliance with UN Security Council sanctions and strengthen enforcement across all regulated sectors.
Pillar 3: Enabling Environment
- Technological Integration (RegTech): Adopt advanced analytics, AI, and big data solutions to detect and combat financial crime.
- Digital Payments & Virtual Assets Oversight: Establish licensing and regulation (through VARA) to manage risks associated with cryptocurrencies and other fintech innovations.
- Combating Trade-Based Money Laundering (TBML): Collaborate with customs, free zones, and financial institutions to address trade-related laundering risks.
- Monitoring & Evaluation: Implement a robust framework for measuring progress, with quarterly reporting to the National Committee and regular public updates.
Enforcement and Supervision
The strategy builds on Cabinet Decision No. 109 of 2023 concerning UBO requirements and registers. The General Secretariat of the National Committee, activated in December 2024, is now responsible for coordinating implementation across ministries and regulators.
Key sectors under scrutiny include banking, real estate, precious metals, auditors, lawyers, and virtual asset service providers. Regulators are actively conducting inspections and issuing multi-million dirham penalties to firms that fall short of compliance standards.
Implications for Businesses
The strategy introduces stronger compliance expectations for companies, including:
- Rigorous Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk clients.
- Mandatory use of the goAML platform for filing Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs).
- A requirement to retain records for at least five years.
- Appointment of internal compliance officers, staff training, and regular independent audits.
- Greater emphasis on proactive risk management, particularly in relation to digital assets and cross-border trade.
References
- Gulf Business – UAE unveils new AML/CFT/CPF national strategy 2024–27
- UAE Ministry of Foreign Affairs – National AML/CFT/CPF Strategy 2024–2027
- Freshfields Risk & Compliance – UAE AML/CFT framework update
- Fintech Global – UAE AML/CFT Strategy 2025 framework
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