Posted inOpinion

A bold step towards global leadership in financial crime prevention

With its new national strategy, the UAE is not only fortifying its own financial system but emerging as a global model in the evolving fight against economic crime

UAE National Strategy for AML/CTF/CFP (2024-27)
National Strategy 2024-27 is testament to the nation’s unwavering commitment to battling financial crime and protecting the integrity of the global financial system. Image: Shutterstock

If the world is to win the fight against financial crime, nations must be willing to evolve — adapting their legal frameworks and enforcement networks to keep pace with ever-more sophisticated criminal enterprises.

Organised financial criminals do not stand still. They constantly exploit new technologies, vulnerabilities, and global markets, requiring an equally dynamic response from governments and regulators. The latest publication of the UAE’s National Risk Assessment (NRA) provides a critical, data-driven understanding of the threats we face and the systemic weaknesses they seek to exploit.

Crucially, the NRA does more than diagnose risks—it lays out actionable solutions. Its findings have directly shaped the UAE’s second National Strategy for AML/CTF/CFP (2024-27), a proactive and forward-thinking roadmap designed to strengthen our defenses, reinforce global cooperation, and ensure that economic crime has no safe haven within our borders or beyond.

An indication of just how seriously we take financial crime, and how it is prioritised, comes from the fact that this Strategy has been pored over and agreed at the highest levels of our society, starting at the top with the entire UAE Cabinet and the Higher Committee Overseeing the National Strategy for AML/CFT, chaired by HH Sheikh Abdullah bin Zayed Al Nahyan, UAE’s Deputy Prime Minister and Minister of Foreign Affairs.

Following the reconstitution of key AML committees in the UAE, which has centralised efforts, the responsibility for implementing the National Strategy 2024-27 has been charged to the General Secretariat for the National Committee for Anti-Money Laundering and Combating of Terrorism Financing and Illegal Organisations. The General Secretariat’s operations are run by the employees of the now defunct Executive Office of Anti-Money Laundering and Counter Terrorism Financing, and has taken over its rights and obligations.

We don’t believe in talking but doing, in making an impact. Consequently, ours is a risk-based strategy and resources are concentrated where they can have the most effect. It’s a ‘whole-of-government’ approach, involving numerous offices of our public service, targeting complex financial crimes including fraud, those involving virtual assets, new technologies like AI, cash-related products and services, remittances and incomplete company documentation.

The UAE National AML/CFT/CFP Committee through its General Secretariat coordinates the activities of more than 90 domestic stakeholders to ensure compliance with international standards and successful implementation of our AML/CFT drive. To assist them, digital tools have been adopted and adapted, including statistics and performance monitoring platforms and case management system.

We’re expanding and raising the profile of the fight against economic crime:

  • We will continue to expand by integrating local, Emirati talents and increasing the number of AML/CFT professionals, ensuring a robust and globally competitive workforce capable of tackling financial crime at every level
  • We’ve signed 48 mutual legal assistance treaties (MLATs) and there are plans for the signing of new MLATs in 2025 and 2026
  • UAE supervisory authorities are raising awareness about AML/CTF and increasing their own visibility. The six supervisory authorities made a combined 828 on-site visits in 2022 and 4,190 in 2023

Our 2024-27 Strategy extends beyond paying mere lip-service to international standards. It’s a clear statement of our ambition to further enhance the country’s status as a center of financial excellence and a leading partner for trade and investment. It lays the groundwork for a secure national economy, in which both citizens and companies are protected from crime and are able to flourish.

In August 2024, the country’s Ministry of Economy suspended 32 local gold refineries for failing to follow AML rules and charged them with 256 violations. Image: Shutterstock

In November 2021, the Ministry of Economy announced a UAE-wide Good Delivery Standard to incentivise market participants to align with international best practices. These measures are already showing positive results: from 2021, suspicious activity reports or SARs increased from 223 to 6,432, indicating heightened vigilance; inspections have increased by 37,025 per cent; and we have taken clear, decisive enforcement action, including the imposition of AED 78,650,000 fines.

While these accomplishments are noteworthy, the journey has come with its set of complexities. Navigating geopolitical trends and shifts, especially in a dynamic and globalised economy like the UAE’s, presents both challenges and opportunities for growth.

Misunderstandings about our approach to sanctions regimes persist. We are determined to combat financial crime. We’ve achieved positive results. For instance for 2024:

  • International cooperation remained a cornerstone of the UAE’s strategy, with the number of Mutual Legal Assistance Treaties (MLATs) increasing from 36 in 2021 to 48 in 2024. The country also maintained a high 83 per cent response rate for extradition requests, reinforcing its reputation as a trusted global partner.
  • Confiscated assets more than doubled, reaching AED 5.2 billion in 2024. In 2023, the UAE seized assets worth over AED 2.348 billion related to AML breaches, showcasing the country’s enhanced enforcement capabilities.
  • Regulatory supervision intensified, with field inspections rising by 11 per cent from 2023 and an overall 409 per cent increase since 2022. Authorities exceeded planned inspection targets, ensuring higher levels of compliance across regulated entities.
  • In August 2024, the UAE Ministry of Economy suspended 32 local gold refineries for failing to follow AML rules and charged them with 256 violations. The suspensions ran between July – October 2024, with the 32 refineries accounting for 5 per cent of the UAE’s gold sector.

The UAE also regards the private sector as a key partner in the fight against financial crime and maintains a strategic dialogue with financial institutions and non-financial professions and businesses. At the heart of this conversation is the national public-private partnership initiative, which is the first of its kind in the MENA region.

The country’s aspirations are not limited to its own borders. The Strategy is a bold declaration of our aim to play a more prominent role within international bodies dedicated to fighting financial crime, and we were delighted to have the honour as an observer at the APG of hosting its annual meeting in Abu Dhabi in September last year.

By positioning itself as a model for other advanced countries, the UAE is not only making financial activity in the nation more secure it is also contributing to international efforts to combat economic crime. We have joined the Eurasia Group and Asia/Pacific Group as an observer nation, and are holding the co-presidency of MENAFATF with the Kingdom of Jordan for 2025-27.

UAE financial crime
The UAE regards the private sector as a key partner in the fight against financial crime and maintains a strategic dialogue with financial institutions and non-financial professions and businesses

Our Strategy 2024-27 is testament to the nation’s unwavering commitment to battling financial crime and protecting the integrity of the global financial system. It is a strategic, forward-looking plan that builds on past successes while addressing the complex challenges of the future.

We’re not only safeguarding our own financial system but following our aspiration to be a global leader in the fight against financial crime. As other nations grapple with the ever-evolving nature of financial threats, the UAE serves as a beacon of best practices, underscoring the importance of adaptability, collaboration, and sustained commitment in this vital, never-ending, constantly evolving struggle.

Our philosophy is clear: the Emirates is a willing, ready and effective partner in the fight against financial crime, wherever and however it occurs.

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Hamid Al Zaabi

Hamid Al Zaabi

His Excellency Hamid Al Zaabi serves as the Secretary General and Vice-Chair of the UAE's National Anti-Money Laundering and Combating Financing of Terrorism and Financing of Illegal Organisations Committee...