Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of
information
Agreements in place?
Has entered into agreements on avoidance of double
taxation & evasion of taxes with the Arab Council of
Economic Unity, China, Finland, Italy, Indonesia, Japan,
Romania and Singapore. Has also entered into
Memoranda of Understanding re aml and terrorist
financing with Armenia, Brazil, Bermuda, Belgium,
Portugal, Serbia, Lebanon, Estonia, Monaco, Isle of
man, Nigeria, Croatia, South Africa, Cook Islands,
Macedonia, Malawi, Philippines and Montenegro.
.
Sanctions:

November 28, 2011  -  The Arab League (comprising 22 Arab
member states), of which this country is a member, has approved
imposing sanctions on Syria. These include: -

* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's
government

The declaration also calls on Arab central banks to monitor
transfers to Syria, with the exception of remittances from Syrians
abroad.

For further information, click here


The Arab League (comprising 22 Arab member states), of which
this country is a member, has boycotted Israel in a systematic
effort to isolate Israel economically in support of the Palestinians,
however, the implementation of the boycott has varied over time
among member states..

There are three tiers to the boycott. The primary boycott prohibits
the importation of Israeli-origin goods and services into boycotting
countries. The secondary boycott prohibits individuals, as well as
private and public sector firms and organizations, in member
countries from engaging in business with any entity that does
business in Israel. The Arab League maintains a blacklist of such
firms. The tertiary boycott prohibits any
entity in a member country from doing business with a company or
individual that has business dealings with U.S. or other firms on
the Arab League blacklist.

____________________________________________________

Offshore Jurisdiction Blacklists:

As a recognised offshore finance jurisdiction this country may fall
under various country offshore jurisdiction blacklists.

____________________________________________________

US State Department Money Laundering Report - 2012:

The United Arab Emirates (UAE) is the primary transportation and
trading hub for the Persian Gulf States, East Africa, and South
Asia. Its robust economic development, political stability, and
liberal business environment have attracted a massive influx of
people, goods, and capital which may leave the country
vulnerable to money laundering activity. Dubai, especially, is a
major international banking and trading center. The potential for
money laundering is exacerbated by the large number of resident
expatriates (roughly 80% – 85% of total population) who send
remittances to their homelands.

A significant portion of the money laundering/terrorist financing
(ML/TF) activity in the UAE is likely related primarily to proceeds
from illegal narcotics produced in South West Asia. Narcotics
traffickers from Afghanistan, where most of the world’s opium is
produced, are increasingly reported to be attracted to the UAE’s
financial and trade centers. Groups operating primarily outside
the country almost certainly control the funds. Domestic public
corruption contributes little to money laundering or terrorist
financing.

Regional hawalas and associated trading companies in various
expatriate communities, most notably the Somalis, have
established clearinghouses, the vast majority of which are not
registered with the UAE government. Likewise, the UAE’s
proximity to Somalia has generated anecdotal reports suggesting
some influx and/or transit of funds derived from piracy. There is
no significant black market for smuggled goods in the UAE, but
contraband smuggling (alcohol) probably generates some funds
that are laundered through the system. There are some
indications that trade based money laundering occurs in the UAE
and that such activity might support terrorist groups in
Afghanistan, Pakistan and Somalia.

Other money laundering vulnerabilities in the UAE include
exploitation of cash couriers, the real estate sector, and the
misuse of the international gold and diamond trade. The country
also has an extensive offshore financial center and 38 free trade
zones (FTZs). There are over 5,000 multinational companies
located in the FTZs, and thousands more individual trading
companies. Companies located in the free trade zones are
considered offshore or foreign entities for legal purposes.
However, UAE law prohibits the establishment of shell companies
and trusts.

For additional information focusing on terrorist financing, please
refer to the Department of State’s Country Reports on Terrorism,
which can be found here: http://www.state.gov/j/ct/rls/crt/

Do Financial Institutions engage in currency transactions related
to international narcotics trafficking that include significant
amounts of US currency; currency derived from illegal sales in the
U.S.; or that otherwise significantly affect the U.S.: no

Criminalization of Money Laundering:

“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes

Legal persons covered: criminally: YES civilly: YES

Know-your-customer (KYC) rules:

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES

KYC covered entities: Banks, hawalas, money exchange houses,
finance companies, securities brokers, and insurance companies

Suspicious Transaction Reporting (STR) Requirements:

Number of STRs received and time frame: 479 in the first quarter
of 2011

Number of CTRs received and time frame: Not available

STR covered entities: Banks, hawalas, money exchange houses,
finance companies, securities brokers, and insurance companies

Money Laundering Criminal Prosecutions/Convictions:

Prosecutions: Not available

Convictions: Not available

Records exchange mechanism:

With U.S.: MLAT: NO Other mechanism: YES

With other governments/jurisdictions: YES

The United Arab Emirates is a member of the Middle East and
North Africa Financial Action Task Force (MENAFATF), a Financial
Action Task Force (FATF)-style regional body. Its most recent
mutual evaluation can be found here: http://www.menafatf.
org/images/UploadFiles/UAEoptimized.pdf

Enforcement and implementation issues and comments:

The Government of the UAE has shown some progress in
enhancing its AML/CFT program; however, several areas
requiring further action by the UAE Government (UAEG) remain.
The UAEG should increase the capacity and resources it devotes
to investigation of ML/TF both federally at the Anti-Money
Laundering/Suspicious Cases Unit (AMLSCU) and at emirate-level
law enforcement. AMLSCU needs to improve its timely financial
information sharing capability to conform to international
standards. The AMLSCU also needs additional resources to be
able to execute its mandate of hawala supervision – currently it is
not capable of supervising the vast number of hawalas in the
country or enforcing hawala compliance.

Although UAE legislation includes a provision prohibiting tipping
off, the provision is very narrow and does not appear to address
the disclosure of STR filings to third parties. Additionally, the
Central Bank regulations appear to require institutions to notify
customers of suspicions regarding their accounts. This would
appear to contradict any tipping off prohibitions.

Although firms operating in the Dubai International Financial
Center (DIFC) are subject to the AML law, the Dubai Financial
Services Authority (DFSA) has issued its own anti-money
laundering regulations and supervisory regime, which has caused
some ambiguity about the Central Bank’s and the FIU’s respective
authorities within the DIFC.

In September 2011 the UAEG enacted an inbound and outbound
cash declaration regulation covering financial instruments valued
at more than DHS 100,000 (approximately $27,000), an amount
above the desired standard but consistent with the traditional
cash-based economy. Law enforcement and customs officials
should conduct more thorough inquiries into large declared and
undeclared cash imports into the country, as well as enforce
outbound declarations of cash and gold utilizing existing
smuggling laws.

Law enforcement and customs officials should proactively develop
cases based on investigations, rather than wait for STR-based
case referrals from the AMLSCU. All facets of trade-based money
laundering should be given greater scrutiny by UAE customs and
law enforcement officials, including customs fraud, the trade in
gold and precious gems, commodities used as counter-valuation
in hawala transactions, and the abuse of trade to launder
narcotics proceeds. The UAEG should expand follow-up with
financial institutions and the Ministry of Social Affairs regarding
regulations on charities to ensure their registration at the federal
level. The UAE should also continue its regional efforts to
promote sound charitable oversight. The cooperation between the
Central Bank and the DFSA needs improvement, with lines of
authority clarified. Moreover, the absence of meaningful statistics
across all sectors is a significant hindrance to the assessment of
the effectiveness of the AML/CFT program.

____________________________________________________

US State Dept Narcotics Report 2012:

Although not a narcotics-producing country, the UAE’s proximity
to Afghanistan, Pakistan, and Iran and its position as an
international transportation hub with active air and sea ports have
made the country a target for the transshipment of heroin and
other narcotics smuggled to Europe, Asia, and Africa, and less
significantly, to the United States. Factors that render the UAE
vulnerable to exploitation by narcotics traffickers include high
volumes of shipping through UAE ports, Dubai’s and, increasingly,
Sharjah’s role as regional transportation hubs, and the UAE’s
long (700 km) coastline and porous land border with Oman.

Drug seizures in the last two years indicate that trafficking groups
may be increasing their use of the UAE as a staging point to
warehouse, stockpile, and distribute narcotics such as Afghan
heroin and hashish, precursor chemicals, and large quantities of
illegal prescription pills for future sale and re-shipment, rather
than simply as a quick transit point. The primary drug threats in
the UAE for transshipment smuggling purposes are southwest
Asian heroin, hashish, Iranian methamphetamine, and Colombian
cocaine. Small amounts of heroin have been shown to be
smuggled to the UAE through its major airports via internal body
smuggling, while larger amounts are smuggled via shipping
containers. Hashish is smuggled on small wooden vessels called
dhows or via vehicles from Oman to the UAE. There are
indications that Iranian methamphetamine smuggling, en route to
Asia, has increased in the past year. Methamphetamine
smugglers have used a variety of smuggling techniques to include
body carrying and hidden compartments in luggage or electronic
devices. The smuggling of cocaine appears to be bound primarily
for Africa. Travel patterns indicate that cocaine smugglers make
use of non-stop flights between Sao Paulo and Dubai, then
connect to flights to Ghana, Ethiopia, or Zimbabwe. There is no
evidence of any major drug cultivation and/or production in the
UAE.

UAE authorities have stopped 828 attempts to smuggle drugs into
the country from January through early October 2011. The
authorities have seen an increase of body smuggling drug
concealment methods in the past year. Drug seizures in recent
months indicate a rise in the use of female drug smugglers. Drug
trafficking is a serious crime in the UAE, and the nation has a zero
tolerance policy towards illegal drug use. A typical sentence for
drug possession is four years. Drug trafficking can carry the
death penalty. In practice; however, sentences vary widely
depending on the severity of the case as it relates to UAE security.

While the rate of illegal drug use in the UAE is low by international
standards, the most common drugs of abuse in the UAE are
hashish and illegal pharmaceutical drugs. Captagon is an
amphetamine-related drug and may be the most widely available
drug in the Persian Gulf countries. Anecdotal reporting suggests
that there also is a substantial market in the UAE for counterfeit or
illegally-obtained prescription drugs. Demand for heroin in the
UAE is small.

The UAEG is aware of the threat to its citizens and residents from
drugs and has made significant commitments of both human
resources and funding towards building new drug control
institutions and conducting counter-narcotics law enforcement
operations. In 2011, the UAE continued to advance its national
drug strategy focusing on intensifying security at the country's air
and sea ports and patrols along the coastline. The UAE strives to
reduce demand for illegal drugs through educational campaigns,
enforcing harsh penalties for trafficking, and rehabilitating drug
addicts. In mid-2011, the Dubai Police Department launched an
interactive Internet portal for crime fighting. The portal aims to
enhance communication with the public and allow private
individuals to post information and potential security issues
anonymously. The service generated 14,202 tips as of early
October 2011.

The UAE is a party to the 1988 UN Drug Convention. The UAE
also is a party to the UN Convention against Transnational
Organized Crime and the UN Convention against Corruption. A
United Nations Office on Drug and Crime (UNODC) semi-regional
office, funded by the UAE government, opened in summer of
2010 in the UAE. The United States and the UAE will continue to
work together to discourage narcotics trafficking and related
financial crimes and to protect citizens from the scourge of drug
abuse.

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 2)

The United Arab Emirates (UAE) is a destination for men and
women, predominantly from South and Southeast Asia, who are
subjected to forced labor and forced prostitution. Migrant workers,
who comprise more than 90 percent of the UAE’s private sector
workforce, are recruited from India, Pakistan, Bangladesh, Nepal,
Sri Lanka, Indonesia, Ethiopia, Eritrea, China, Thailand, Korea,
Afghanistan, Iran, and the Philippines. Women from some of these
countries travel willingly to the UAE to work as domestic servants,
secretaries, and hotel cleaners, but some are subjected to
conditions indicative of forced labor, including unlawful withholding
of passports, restrictions on movement, nonpayment of wages,
threats, or physical or sexual abuse. Restrictive sponsorship laws
for foreign domestic workers often give employers power to
control their movements, threaten them with abuse of legal
processes, and make them vulnerable to exploitation. Men from
India, Sri Lanka, Bangladesh, and Pakistan are drawn to the UAE
for work in the construction sector, but are often subjected to
conditions of forced labor, including debt bondage as they
struggle to pay off debts for recruitment fees. Migrant workers
were vulnerable to forced labor, particularly in the construction
sector, as some employers declared bankruptcy and fled the
country, effectively abandoning their employees. Women from
Eastern Europe, Central Asia, Southeast Asia, the Far East, East
Africa, Iraq, Iran, and Morocco are subjected to forced prostitution
in the UAE.

The Government of the United Arab Emirates does not fully
comply with the minimum standards for the elimination of
trafficking; however, it is making significant efforts to do so. This
year, the government established a special court to hear human
trafficking cases in Dubai and opened two new shelters for victims
of trafficking. The government continued to prosecute and punish
sex trafficking offenders, though its efforts to combat forced labor
remained extremely weak. Although the government
acknowledges the need to address forced labor, there continued
to be no discernible anti-trafficking efforts against the forced labor
of temporary migrant workers and domestic servants. These
victims remained largely unprotected and, due to the lack of
systematic procedures to identify victims of forced labor among
vulnerable populations, they may be punished for immigration and
other violations.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: The United Arab Emirates government continued to
build its counterterrorism capacity and worked to strengthen
international cooperation to counter terrorism. In 2010, the
Government of the United Arab Emirates (UAE) improved border
security measures and renewed counterterrorist financing efforts.
In addition, prominent officials and religious leaders continued to
publicly criticize extremist ideology.

2010 Terrorist Incidents: On October 29, UAE authorities foiled a
terrorist plot when authorities in Dubai discovered an explosive
device in a package transiting from Yemen to the United States
via aircraft. Al-Qa’ida in the Arabian Peninsula claimed
responsibility for the plot.

Legislation and Law Enforcement: The UAE participated in the
Megaports and Container Security Initiatives (CSI). Under the CSI,
which became operational at Port Rashid and Jebel Ali Port in the
Emirate of Dubai in 2005, three U.S. Customs and Border
Protection officers co-located with the Dubai Customs Intelligence
Unit at Port Rashid. In 2010, the UAE Ministry of Interior and the
Abu Dhabi Customs Authority signed memoranda of cooperation
with Immigration and Customs Enforcement (ICE). These
agreements facilitated ICE assistance to provide technical support
and instruction in the establishment of two separate training
academies to further build Emirati Customs and Police capacity.
On May 10, Abu Dhabi Customs signed a memorandum of
understanding with ICE to exchange investigation-related
information obtained at ports of entry, which was the first U.S. Law
Enforcement information-sharing agreement with the UAE.

Countering Terrorist Finance: The UAE continued efforts to
strengthen its institutional capabilities to counter terrorist
financing, but challenges remained. The Central Bank signed a
memoranda of understanding (MOU) with regional financial
intelligence units, building on cooperation initiated in 2008, and
performed anti-money laundering training both locally and
regionally. On October 25, the UAE’s Financial Intelligence Unit,
the Central Bank's Anti-money Laundering and Suspicious Cases
Unit, signed an MOU with the Federal Customs Authority to
facilitate information sharing in an effort to improve the UAE's anti-
money laundering apparatus.

The UAE is a member of the Middle East and North Africa
Financial Action Task Force (MENAFATF), a FATF-style regional
body, and its most recent mutual evaluation was adopted by the
plenary in 2008. It is also a member of the Gulf Cooperation
Council and through this body, the UAE is also a member of the
FATF. The UAE hosted the February 2010 FATF plenary meeting.
Although the UAE has taken important steps to address hawala
remittances, further vigilance is required.

The UAE Central Bank has provided training programs to financial
institutions on money laundering and terrorist financing.
Continuing initiatives from previous years, the United States and
the UAE worked together throughout the year to strengthen
efforts to combat Bulk Cash Smuggling (BCS), in particular from
countries at higher risk of illicit finance activity. The UAE is an
enthusiastic proponent of BCS training and has encouraged
MENAFATF members to undertake the training.

Regional and International Cooperation: After the Japanese oil
tanker M Star was damaged in the Strait of Hormuz in July, UAE
authorities allowed U.S. Navy divers to do a forensic inspection of
the ship while docked at the port of Fujairah.

The UAE hosted a plenary meeting for the Global Initiative to
Combat Nuclear Terrorism on June 22, which was attended by
representatives from 47 countries.

Countering Radicalization and Violent Extremism: In order to
prevent extremist preaching in UAE mosques, the General
Authority of Islamic Affairs and Endowments provided prescribed
guidelines for all Friday sermons and monitored compliance. The
UAE worked to keep its education system free of radical
influences and emphasized social tolerance and moderation.
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
White
?
Is it on EU 'white' list of equivalent jurisdictions?
N
?
Offshore Finance Center (Original IMF List)?
Y
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
PC
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
Y
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
N
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o Delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
28 (out of
183)
28 (out of
178)
?
Ease of doing business (World Bank)
33 (out of
183)
40 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2008
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
5
15
18
11
0
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
P
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
L
 
17. Sanctions
P
5. Customer due diligence
N
 
18. Shell banks
P
6. Politically exposed persons
N
 
19. Other forms of reporting
C
7. Correspondent banking
N
 
20. Other NFBP & secure
transaction techniques
P
8. New technologies & non
face-to-face business
L
 
21. Special attention for
higher risk countries
P
9. Third parties and introducers
L
 
22. Foreign branches &
subsidiaries
L
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
L
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
P
13. Suspicious transaction reporting
N
     
Institutional and other
measures
 
26. The FIU
P
 
31. National co-operation
L
27. Law enforcement authorities
C
 
32. Statistics
P
28. Powers of competent authorities
C
 
33. Legal persons –
beneficial owners
P
29. Supervisors
P
 
34. Legal arrangements –
beneficial owners
C
30. Resources, integrity and training
P
 
 
 
International Co-operation
 
35. Conventions
C
 
38. MLA on confiscation and
freezing
P
36. Mutual legal assistance (MLA)
L
 
39. Extradition
L
37. Dual criminality
L
 
40. Other forms of
co-operation
P
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
N
SR.II Criminalise terrorist financing
L
 
SR VII Wire transfer rules
N
SR.III Freeze and confiscate
terrorist assets
P
 
SR.VIII Non profit
organisations
L
SR.IV Suspicious transaction
reporting
N
 
SR.IX Cross Border
Declaration & Disclosure
N
SR.V International co-operation
L
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if
any of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated
either Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
UNITED ARAB EMIRATES
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
N
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
___________________________________________________

AML News  /  Relevant Information

February 5, 2012  -  Banks in UAE and Qatar stop financing trade with
Iran

Read More (Reuters)

Extracted from 2011 IMF Report  -  IMF Executive Board conclusion on
economic conditions

Read Conclusion (internal link)


Links:

Anti Money Laundering and Suspicious Cases Unit (AMLSCU)

Worldwide AML Legislation (International Bar Association)
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012