2022

ANNUAL
REPORT
UAE Financial Intelligence Unit (UAEFIU)

Email: [email protected] Website: www.uaefiu.gov.ae

TABLE OF
CONTENT
• FOREWORD 1
• MESSAGE FROM THE CHIEF OF UAEFIU 3
• UAE AML/CFT INSTITUTIONAL FRAMEWORK 4
• VISION, MISSION AND VALUES 6
• ORGANISATIONAL CHART AND BRIEF HISTORY 8
• UAEFIU LEGAL MANDATE 10
• UAEFIU SECTIONS 11
• OVERVIEW OF 2022 FIGURES 13
• UAEFIU FUNCTIONS 14

1. International Cooperation 14
2. Operational Analysis 16
3. Research and Strategic Analysis 20
4. Domestic Cooperation 24
5. Policy 26
6. Outreach 28
7. Strategy 30
8. Systems Infrastructure 31

• ANNEX 35
• AML/CFT Legal Framework Updates in 2022 36
• Key 2022 Statistics 37

1. International Cooperation 37
2. Operational Analysis 40
3. Domestic Cooperation 42
4. List of Risk Indicators 44

• Glossary 48

UAE Financial Intelligence Unit (UAEFIU)

FOREWORD

FOREWORD
FOREWORD
FOREWORD
H.E. Khaled Mohamed Balama
Chairman, NAMLCFTC

1 UAE Financial Intelligence Unit (UAEFIU)

 I am pleased to present the 2022 Annual Report of UAE Financial Intelligence
Unit (UAEFIU). The report details some of the UAEFIU’s major successes over the
past year.

In 2022 more than AED 452,529,528 has been frozen based on UAEFIU analysis,
total of 63 MoUs have been signed with counterpart FIUs internationally till end of
2022 and over 8,000 people have participated in UAEFIU awareness programs.

I would like to take this opportunity to express my gratitude to UAEFIU

management and staff, and to all UAEFIU stakeholders for their support and
commitment to achieve UAEFIU vision of being a leading FIU in the protection of
global financial integrity, peace and security.

The UAEFIU has made clear progress towards this vision in 2022, and I am
convinced that it will remain steadfast in its pursuit of excellence in the fight
against money laundering, terrorist finance and associated crimes (ML/TF) for their
transnational nature.

Addressing this threat means that an ambitious and integrated whole of

government approach is needed to tackle it. That is why the leadership, talent, and
commitment which I see every day from the UAEFIU and its officers fills me with
great confidence.

As this report demonstrates, the UAEFIU is rapidly developing a proven track record
of responding robustly to changing circumstances and I am confident they will
continue to provide strong standing in the year ahead.

H.E. Khaled Mohamed Balama

Chairman, NAMLCFTC

2 UAE Financial Intelligence Unit (UAEFIU)

MESSAGE
I am delighted to present the 2022 Annual Report, which shows the significant
progress the UAEFIU had the past year. Our mission to protect the UAE and its
communities from the global threat against money laundering, terrorist finance and

FROM
associated crimes (ML/TF).

This Annual Report sets out the significant successes we have had in year 2022, in

THE CHIEF
leading that fight. I am continually proud of our achievements and the determination
of our officers, often working with others in holistic government approach.

OF UAEFIU
We operate with partners across law enforcement, government, the public, private
and other sectors in the UAE and internationally. Without them, many of the
operational outcomes in this document would not have been possible.

This year has seen significant investment in our technology, people and processes
to enhance our abilities and deliver new national capabilities. This has led to an
increasingly sophisticated understanding of the key threats the UAE faces, which
has enhanced our ability to make informed decisions about those threats and,
importantly, respond to them in an extensive and dynamic way.

Now more than ever, it is essential that the UAEFIU has the right capabilities, powers,
structure and international reach to disrupt and deter money laundering, terrorist
finance and associated crimes (ML/TF).

This report details our progress in understanding the intelligence picture and
ensuring relentless investigation, and shows how we are building new capabilities to
protect the UAE.

I am honoured to have the privilege to lead the UAEFIU and remain committed to
delivering our vision to be a leading FIU in the protection of global financial integrity,
peace, and security.

Ali Faisal Ba’Alawi

Chief of the UAEFIU

3 UAE Financial Intelligence Unit (UAEFIU)

UAE AML/CFT
INSTITUTIONAL FRAMEWORK
Since 2002, the UAE has built a comprehensive Anti-Money Laundering The NAMLCFTC established eight subcommittees with different
and Countering the Financing of Terrorism (AML/CFT) institutional specialties related to AML/CFT. The subcommittees are made up of
framework supported by a strong legal structure, which has been further technical members in their fields from different competent authorities,
enhanced throughout the years bearing in mind the evolving nature of the including the UAEFIU, as follows2 :
AML/CFT landscape.
1. The Sub-Committee for Technical Compliance of the United Arab
The framework includes national committees, judicial authorities, Emirates’ Mutual Evaluation Report
regulatory authorities, law enforcement authorities, security agencies, 2. The Sub-Committee for Money Laundering Crimes Investigative
company registrars, and the Financial Intelligence Unit. Authorities in the United Arab Emirates
3. The Sub-Committee for Supervisory Authorities in the United Arab
The National Anti-Money Laundering and Combating Financing of Emirates
Terrorism and Financing of Illegal Organizations Committee (NAMLCFTC)1 4. The Sub-Committee for National Risk Assessment of Money-
established in 2002, is the primary body for policy-making and issuing Laundering, Terrorism Financing and Illegal Organizations Financing
regulations to combat money laundering (ML) and the terrorism financing Risks in the United Arab Emirates
(TF) in the UAE, with a clear legal mandate described in Article 11 and 12 of 5. The Sub-Committee for Combatting the Financing of Terrorism
the Decretal Federal Law No. 20 of 2018 regarding Anti-Money Laundering and the Financing of Illegal Organizations and the Financing of
and Combating Financing of Terrorism and Illegal Organizations (AML Law). Proliferation in the United Arab Emirates
6. The Sub-Committee of Companies Registrars in the United
The NAMLCFTC is chaired by H.E. the Governor of the Central Bank of the Arab Emirates
UAE (CBUAE) and has 44 permanent members from 32 federal and local 7. The Sub-Committee for Managing and Follow-up of International
competent government authorities including the UAEFIU, and a dedicated Co-operation Requests Related to Money Laundering and Related
secretariat that handles all of the administrative work of the NAMLCFTC, Predicate Crimes and Combatting the Financing of Terrorism
its meetings and decisions. 8. The Sub-Committee on Public-Private Partnership for Countering
Money Laundering and Terrorism Financing
1
https://www.namlcftc.gov.ae/en
2
https://www.namlcftc.gov.ae/en/about/namlcftc-structure/

4 UAE Financial Intelligence Unit (UAEFIU)

The NAMLCFTC created an AML/CFT National Strategy of 2020-2023 the UAE, which has ministerial level members from the Ministry of Foreign
as a road map for all competent authorities to follow and to support Affairs, Ministry of Interior, Ministry of Finance, Ministry of Justice, Ministry
in allocating resources more effectively and efficiently across the of Economy, Central Bank of the UAE, Federal Authority for Identity,
institutional framework established to prevent, detect and deter ML and Citizenship, Customs & Ports, and the security agencies.
TF within the UAE. This strategy identified 12 distinct strategic goals3,
based on the risks identified in the National Risk Assessment and the The Higher Committee established The Executive Office of Anti-Money
Financial Action Task Force’s (FATF) Mutual Evaluation Report (MER), Laundering and Counter Terrorism Financing4 in 2021 through
which outlines specific actions for all competent authorities within the Cabinet Resolution No. 10 of 2021. Among its tasks is to oversee the
institutional framework. implementation of the National AML/CFT Strategy and the National
Action Plan, and to monitor and assess any risks related to ML/TF, financing
In 2020, the UAE Cabinet established the Higher Committee Overseeing of illegal organisations, and financing proliferation, in coordination with the
the National Strategy on AML/CFT (the Higher Committee), chaired by NAMLCFTC and its subcommittees.
H.H. Sheikh Abdullah Bin Zayed Al Nahyan, Minister of Foreign Affairs of

3
https://www.namlcftc.gov.ae/en/more/uae-strategy/
4
https://amlctf.gov.ae/

5 UAE Financial Intelligence Unit (UAEFIU)

VISION, MISSION AND VALUES

VISION
MISSION
VALUES

6 UAE Financial Intelligence Unit (UAEFIU)

 To be a leading Financial
Intelligence Unit in the

VISION
protection of global
financial integrity,
peace and security.

MISSION
To produce actionable financial
intelligence for the fight against money
laundering, its predicate offences and

VALUES
terrorist financing, at both the national
and international levels, through
the continuous enhancement
of subject matter expertise,
methods, and technology.

Integrity, Accountability,
Domestic and
International Cooperation,
Confidentiality, and
Proactivity.

7 UAE Financial Intelligence Unit (UAEFIU)

 ORGANISATIONAL
STRUCTURE

8 UAE Financial Intelligence Unit (UAEFIU)

 H.E.
the Governor
Chair of the
NAMLCFTC

Chief of Financial
Intelligence
Unit

Research and System

International Strategic Infrastructure
Cooperation Policy
Analysis

Strategy Domestic Outreach Operational

Cooperation Analysis

Brief History of UAEFIU

In 1998, the Central Bank of the UAE (CBUAE) established a special unit to investigate fraud and suspicious transactions, which was renamed the Anti-
Money Laundering and Suspicious Cases Unit (AMLSCU) in 2002. This unit’s aim, in collaboration with its stakeholders, was to protect the UAE’s economy
from illegitimate activities, including money laundering and terrorism financing.

With the issuance of the Decretal Federal Law No. 20 of 2018 on Anti Money Laundering and Combatting Financing of Terrorism and Financing of Illegal
Organizations (AML Law) and its Executive Regulation (Cabinet Decision No. 10 of 2019), the unit was renamed the Financial Intelligence Unit (UAEFIU).

9 UAE Financial Intelligence Unit (UAEFIU)

LEGAL MANDATE
The UAEFIU gains its legal mandate and powers mainly from Article The UAEFIU has the legal powers to exchange information with its
No. (9) of the AML Law and Articles (40) to (43) of the AML By-law as an counterparts in other countries according to international agreements
independent unit established within the CBUAE to exclusively receive, to which the UAE is a party or bilateral agreements signed by the UAEFIU
analyse, and disseminate Suspicious Transaction Reports (STRs) from all with its counterparts governing bilateral cooperation or conditional
Reporting Entities, including Financial Institutions (FIs), Designated Non- upon reciprocity.
Financial Businesses and Professions (DNFBPs), and Virtual Asset Service
Providers (VASPs), licenced or registered in the UAE.

The UAEFIU has the legal powers to request any information from any
competent authority or Reporting Entity deemed necessary to perform its
duties on schedule and in the form determined by the UAEFIU.

10 UAE Financial Intelligence Unit (UAEFIU)

UAEFIU SECTIONS
The UAEFIU organisational chart consists of eight sections, in addition 4. Policy
to the Chief of Financial Intelligence Unit (CoFIU) Office. Each section The section is responsible for developing internal policies, procedures and
has its own roles, responsibilities and Standard Operating Procedure guidelines and collaborating with other sections of the UAEFIU in creating
(SOP) describing its functions and the detailed unified processes to and maintaining SOPs, the section also provide legal advices for the other
achieve each function, in accordance with institutional governance and section in relation to their daily operations. In addition, the section plays
quality assurance, which is considered as a step-by-step guide for the a critical role within the UAE AML/CFT framework by supporting the
UAEFIU staff. concerned authorities in drafting and updating AML/CFT legislations,
and collaborating with supervisory authorities in developing AML/CFT
1. Strategy Section regulations and guidance.
The main function of the section is to support the UAEFIU in implementing
its mission mainly through developing yearly operational plans, in line with 5. Outreach
the UAE National Strategy on AML/CFT and the National Action Plan, and The section is responsible for engaging with the reporting entities and
overseeing their implementation. recommending best practice to enhance the AML/CTF compliance
and STR reporting. The section also collaborates with domestic and
2. International Cooperation Section international stakeholders to organize and develop training programs in
The primary function of the section is to disseminate and receive, both relation to AML/CFT and financial crime. Internally, the section is planning
pursuant to incoming and outgoing requests, information relevant to and implementing a yearly training plan for the UAEFIU staff.
combatting ML, TF, proliferation financing (PF), and associated predicate
offenses to and from its international partners. 6. Research and Strategic Analysis Section
The primary function of the section is to carry out strategic, studies,
3. Domestic Cooperation Section typology reports, whitepapers and statistical reviews related to money
The main function of the section is to serve as the focal point for laundering, terrorist financing and other activities relating to predicate
engagement between the UAEFIU and all competent authorities in offences within the UAE and abroad when warranted. The section
the UAE including Public Prosecution (PP), law enforcement authorities examines the available and obtainable information to the UAEFIU and
(LEAs), state security (SS), and supervisory authorities for the exchange of generates analysis reports on the UAE’s financial and trade systems, VASPs
information and intelligence. and DNFBP sectors insofar as they relate to ML/TF and other predicate
5
https://www.uaefiu.gov.ae/en/about-us/mandate/
6
https://www.uaefiu.gov.ae/en/about-us/organisational-structure/

11 UAE Financial Intelligence Unit (UAEFIU)

offences. Ultimately, the section aims to develop the understanding of the potentially nefarious actors in their attempt to launder illicit proceeds,
primary risk drivers of financial crime within the UAE by identifying relevant finance terrorism and overall fund their unlawful activities. This is done by
typologies, patterns, trends, and risk indicators. developing actionable intelligence in the form of activity patterns, targets,
criminal ties, relationships, and networks, leads, criminal profiles and the
7. Operational Analysis Section tracing of funds.
The primary function of the Operational Analysis Section is three-fold.
Firstly, as the designated national receptor of reports, the section is Finally, the section will share this operational intelligence with LEAs, and
building the capabilities to receive STRs, SARs, and other report types other competent authorities, as needed, for further action.
as mandated by the UAE’s laws and regulations from the financial
sector, DNFBPs and VASPs (Reporting Entities), and to collect additional 8. Systems Infrastructure Section
information from the broadest range of national and international sources. The section is responsible for day-to-day activities of administering
UAEFIU-owned systems and applications, website (publicly facing and
Secondly, the section is tasked with analysing the reports and other intranet) management and support, database structures and system
information and data gathered to identify possible illicit activity in the setup/configurations.
financial, DNFBP and VASP sectors, and the economy in general, used by

12 UAE Financial Intelligence Unit (UAEFIU)

OVERVIEW OF 2022 FIGURES

OVERVIEW OF 2022 FIGURES

8,023 3,742
33,459 Participants in the Domestic Cooperation
STRs received UAEFIU awareness programs requests received
(%96 increase compared to 2021) (%12 increase compared to 2021) (%6 increase compared to 2021)

5,453 212 16,503

SARs received Cases disseminated to LEA total Reporting Entities
(%55 increase compared to 2021) (includes 2,543 STRs/SARsother reports) registered in goAML
(%46 increase compared to 2021) (%16 increase compared to 2021)

966 AED 452,529,528 93

international requests and total amount frozen based training sessions and workshops
intelligence received from FFIU on UAEFIU analysis completed by the UAEFIU staff
(5% increase compared to 2021) (481% increase compared to 2021)

477 63
outgoing RFIs/SDs total MoUs signed with counterpart
(24% increase compared to 2021) UAEFIUs as of 31 December 2022
13 UAE Financial Intelligence Unit (UAEFIU)
UAEFIU FUNCTIONS
1. International Cooperation: The objective of this plan is to identify the jurisdictions of strategic
relevance so the UAEFIU can prioritise its actions and focus on enhancing
its information sharing efforts where they make most sense.
International coordination and cooperation are critical elements in the
global fight against money laundering, terrorist finance and associated
In addition, the plan supports the UAEFIU to propose the establishment
crimes (ML/TF) for their transnational nature. The UAEFIU considers the
of bilateral dialogues aimed at improving the understanding of risks of
international cooperation with counterpart FIUs and other international
mutual concern and developing joint strategies to mitigate them through
stakeholders as a matter of priority and a core function.
enhanced information sharing, bilateral dialogue that includes technical
assistance, capacity building programmes, joint projects, and establishing
During 2022, the UAEFIU moved the international cooperation to the
of new MoUs.
next level with methodological bases, by adapting, for the first time,
an “International Engagement Plan” that built on a comprehensive
Part of the plan is to monitor and measure the progress of the operation
methodology with 11 different criteria, including volume of exchange of
and cooperation with the jurisdictions of strategic relevance through
information, principle violations in information requests, transactions
joint key performance indicators (KPIs) between the UAEFIU and the
amount included in STRs/SARs, amount of inward/outward remittances,
counterpart FIUs. The results of the KPIs will be presented at the end
cash declarations, existence of MoU or MLA, and outcomes of the NRA.
of each calendar year as “achievements of cooperation” to the head of
UAEFIU and its relevant counterpart.

14 UAE Financial Intelligence Unit (UAEFIU)

 2022 HIGHLIGHTS
01 03 05
Conducted 59 Sent 283
meetings requests for
with international
stakeholders (including
information
Signed 4 FIUs, Egmont meetings, Received 782 include 235 natural Reviewed its
persons and 286
MOUs engagements with
international
requests for juridical persons, and performance
with strategic
jurisdictions in 2022
organizations,
Bilatelateral Dialogue on
information 194 spontaneous
disclosures to Egmont
by sending surveys to
the top 20 counterpart
to exchange ML/TF UAE government level) include 1219 natural and non-Egmont FIUs. FIUs to measure the
related to financial persons and 1336 effectiveness of the
intelligence juridical persons, and UAEFIU information
184 spontaneous exchanges. The results
disclosures from revealed significant
Egmont and improvement, as for
non-Egmont FIUs. the quality the
satisfaction level
reached 4.2 out of 5 and
as for the timelines it

02 04
reached 3.6 out of 5.

15 UAE Financial Intelligence Unit (UAEFIU)

Operational Analysis

2. Operational Analysis: UAEFIU’s own strategic analysis reports but also in coordination with other
government authorities whereby those authorities had published red flags
specific to their areas within the AML/CTF regime.
One of the core functions of the UAEFIU is to receive Suspicious
Transaction Reports (STRs), Suspicious Activity Reports (SARs), and other
Those red flags were taken into account to allow Reporting Entities (REs)
reports from Reporting Entities, and to analyse them along with related
more flexibility and a wider range of options in terms of choosing RFRs that
information from other sources, and disseminating financial intelligence to
best suit the red flags that they have identified and thus the reason why
law enforcement partners when warranted.
the reporting is taking place .

To identify potential ML/TF cases, the UAEFIU follows a risk-based

As with all processes the changes to the STR/SAR life cycle have been
approach to prioritise and analyse information received and collected
adopted gradually, both when a need arose but also proactively when
from Reporting Entities and other stakeholders, taking into account risk
enhancements to how the UAEFIU could better apply a risk-based
attributes identified through the UAE’s national risk assessment, various
approach to target higher risk typologies were identified.
sectorial risk assessments, and the outcomes of the strategic analysis
conducted.
Triage Function:
The triage function that was set up in late 2021 was further strengthened
Updated STR/SAR Life Cycle:
during 2022 whereby the process was enhanced to create a seamless
Historically, the STR/SAR life cycle included two main system related
handover from the RBA system to the triage team. The triage team takes
gateways or checks by which quality was checked and a risk-based
off where the system intervention ends and looks into higher risk STRs/
approach was applied. This included the usage of Business Rejection Rules
SARs. This team which is made up of seasoned team members further drill
(BRRs) in the reporting system as well as a Risk-Based Approach (RBA)
down into the reports being received to make sure that reports that end up
engine that sits on top of the reporting system and applies the information
being looked at by the analysis teams are of high quality, higher risk, and
from incoming reports to a set of up to 12 risk parameters. This allowed the
will end up in dissemination to law enforcement or the freezing of funds.
UAEFIU to assign a risk factor or score to every STR/SAR received.
The Triage team also makes sure that reports that are moved on for full
During 2022, the UAEFIU received a record number of STRs, SARs and
manual analysis include elements that are important to the UAE from a
other report types. Thus, the STR/SAR life cycle was further enhanced
strategic perspective and that are in and of themselves the beginnings of
in a multitude of ways. Firstly, the list of Reasons for Reporting (RFRs)
cases that are of higher risk and higher concern to both the UAEFIU and
was updated. This was done both in response to the findings of the
LEAs. This includes:

16 UAE Financial Intelligence Unit (UAEFIU)

1. Reports related to possible Terrorism Financing (TF);
2. Reports related to possible Proliferation Financing (PF);
3. Reports related to possible Trade Based Money Laundering (TBML);
4. Reports with international elements including possible laundering of proceeds of international predicate offences;
5. Reports related to possible Professional Money Laundering (PML);
6. Reports related to fraud and fraudulent activities, especially when the fraud is a catalyst for money laundering;
7. Reports that fit into the above prioritisation areas and where funds exist in the accounts being reported and fund freezes may be warranted.

The current STR/SAR life cycle is now more robust with a focus on applying a risk-based approach both via system controls but also by a dedicated team.
This double focus on a risk-based approach before the reports are allocated to analysis teams has led to far fewer reports being closed by the analysis
teams and disseminations being focused on higher risk typologies. It has also been a contributing factor in the larger numbers of disseminations during
2022 when compared to 2021.

Figure 1: Current STR/SAR life cycle

01 02 03 04 05
STRs/SARs Reports that pass the Risk Rating score is High risk STRs/SARs Reports that pass
received via BRRs enter into the RBA assigned to each are triaged based on a triage are assigned
goAML go through system that includes STR/SAR. Higher risk set criteria as per policy to operational
Business Rejection over a dozen parameters. STRs/SARs go into 1st and in line with national analysts for full
Rules (BRRs). This is a system level level manual analysis, risks and investigations manual analysis.
analysis. the triage function. focus areas.

17 UAE Financial Intelligence Unit (UAEFIU)

Quarterly Feedback Report: The reports are also discussed in various forums with REs, most notably in
To help close the loop on reports that are received, the UAEFIU issues a the various roundtable sessions held by the UAEFIU. The feedback from
Feedback Report on a quarterly basis to all reporting entities as well as all Compliance Officers has been positive and the two-way communication
supervisors. Historically, this report included lists of good conduct that between the UAEFIU and REs was one of the catalysts for some of the
was seen in the reports received during the preceding quarter with notes changes in the content of the feedback reports as REs asked for more
on why the conduct was considered good. The reports also included issues information on what happens to their raised reports after the UAEFIU
seen in the reports as a whole with explanations as to why these issues are analyses and disseminates. Such cooperation is important and has become
negative in nature and how REs could rectify them going forward. the standard during 2022.

During 2022, the feedback reports started to change in both tone and with
regards to what information is provided. The average feedback report has
doubled in size and has shifted from a very FIs oriented report to a more
inclusive report where feedback specific to DNFBPs is provided. Aside
from the feedback on good and bad practices, these feedback reports
now include:

1. Statistical analysis of reports received from REs;

2. Highlights on the reporting statistics of various sectors;
3. Explanation of disseminations that took place during the preceding
quarter, including the typologies noted and to which LEAs they were
disseminated;
4. Case studies that highlight emerging typologies or provide good
lessons to the various sectors;
5. Trend alerts where new trends/typologies are noticed;
6. Feedback specific to various DNFBP sectors.

18 UAE Financial Intelligence Unit (UAEFIU)

 2022 HIGHLIGHTS

Disseminations Received Reports Freeze LEAs Feedback

Disseminated 123 proactive Received 78.66% increase Conducted freeze orders to Recieved 147 feedback from
disseminations to the LEAs. in the reports submitted in accounts/amounts in 9 cases LEAs regarding the cases
the reporting system by the included 38 natural persons and dissminated to them, which
FIs and 121% by the 41 juridical persons, for total presents 47% increase
DNFBPs compared to 2021. amount of AED452,529,526. compared to 2021.

19 UAE Financial Intelligence Unit (UAEFIU)

Research and Strategic Analysis

3. Research and Strategic Analysis: the reports was also shared with Reporting Entities through the reporting
system goAML and a public version on the UAEFIU LinkedIn account. For
further information on the identified typologies and patterns, please
As one of the core UAEFIU functions, Strategic Analysis produced four
refer to the published reports. Lists of developed risk indicators are also
thorough reports in 2022, namely:
attached in the annex of this report.

1. Typology report on ‘Fraud Trends, and Typologies’.

2022 Strategic Analysis Reports in Brief:
2. Typology report on ‘Dealers in Precious Metals and Stones’.
3. White paper on ‘Underground Banking: Far East Typology Patterns and
1. Typology report on Fraud, Trends, and Typologies
Schemes’.
Fraud is a criminal offense that refers to intentional deception to secure
4. Statistical review of federal customs data obtained from the Federal
or gain unfair or unlawful profit or deprive the legal right of property
Authority for Identity, Citizenship, Customs & Port Security (ICP) and
ownership. Fraud involves misrepresenting facts either by words or by
the UAE Remittance Reporting System (UAERRS).
conduct, withholding vital information, or even making false statements
made by one party (perpetrator) to another, causing financial or non-
The reports aimed to identify typologies and emerging techniques,
financial or potential loss to another party (victim).
determine vulnerabilities, provide a list of red flag indicators, and illustrate
case samples related to the aforementioned topics using all obtainable
In the UAE, fraud is one of the most common crimes facing the financial
and available information to the UAEFIU.
sector. Fraud crimes are committed daily. While law enforcement and other
bodies trace and prosecute financial criminals, fraudsters develop more
Outreach sessions were conducted for the public and private sectors
sophisticated methods to commit such crimes. According to information
on the outcome of the typology reports; more than 355 participants
collected from the reporting entities and the received suspicious reports
attended the strategic analysis sessions in 2022.
by the UAEFIU in 2022, the estimated losses related to international ‘fund
transfer fraud’ (based) were approximately AED 152 million in 2020 and
The UAEFIU shared the strategic analysis reports with the National Anti-
AED 132 million in 2021. The estimated losses related to the domestic ‘fund
Money Laundering and Combatting the Financing of Terrorism Committee
transfer fraud’ were approximately AED 154 million in 2020 and
(NAMLCFTC), as well as supervisory authorities, the concerned NAMLCFTC
AED 162 million in 2021.
sub-committees, and law enforcement authorities. A sanitized version of

20 UAE Financial Intelligence Unit (UAEFIU)

The examined sample reviewed by the UAEFIU of STRs/SARs and sectoral risk assessments. Therefore, the ML/TF risk of abusing DPMS
ISDs/IRIs underlined the following common fraud patterns and should be well understood and monitored through DPMS conducting
trends: adequate due diligence and risk assessment, recordkeeping, and reporting
suspicious transactions.
• Funds Transfer Fraud or Money Transfer Fraud
• Business E-mail Compromise (BEC) The following typologies and their associated risk indicators
• Scam Fraud constituted the key findings of the UAEFIU strategic analysis on
• Fake Products/Fake Websites Fraud DPMS in 2022, wherein the risk mitigation areas required in the DPMS
• Fake Visa/Ticketing Fraud sector:
• Investment Scam/Fraud Phishing/Vishing
• Forgery/Counterfeit • Trade-based money laundering (TBML) by DPMS entities
• Money laundering through ‘foreign currency exchange’ by DPMS
2. Typology report on Dealers in Precious Metals and Stones entities
Precious metals and stones (PMS) are attractive to criminals and terrorists • Possible gold/cash smuggling via DPMS entities (conflict gold supply
because they offer a high level of liquidity and anonymity, in addition chain)
to their compact size so that they can easily be stored or smuggled. As
such, dealers in precious metals and stones (DPMS) are vulnerable to 3. White paper on Underground Banking: Far East Typology Patterns
exploitation in money laundering (ML) and terrorist financing (TF) schemes. and Schemes
DPMS are considered among the Designated Non-Financial Business The Far East typology of underground banking was first recognised by
and Professions (DNFBPs) under Cabinet Decision No. (10) of 2019 and Financial Institutions (FIs) in the UAE in late 2017. UAE FIs were detecting
its amendments concerning the Implementing Regulation of Decree legal entity clients receiving unreasonably high volumes of large cash
Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating transaction activities followed by multiple outward remittances.
the Financing of Terrorism and Illegal Organizations. Consequently, DPMS From 2018–2019 onwards, the scheme shifted towards the use of clearing
are subject to the DNFBPs requirements, including reporting suspicious cheques and inter-banking transactions while leaving bank accounts with
transactions and any transaction equal to or more than AED 55,000 to the a low or no balance. Afterwards, the said typology continued to employ
UAEFIU, as well as identifying and mitigating any ML/TF risks encountered. rapid movement of funds but through more intersections of different
transaction modes, including inward wires from multiple counterparties,
While the UAE is a major contributor to the global trade of PMS, the internal transfers, cash and cheque deposits, clearing cheques, or through
risk of DPMS being abused for ML/TF purposes is recognized as high in customers’ own accounts.
both mainland and commercial free zone, according to UAE national and

21 UAE Financial Intelligence Unit (UAEFIU)

Subsequently, these transactions are wired outwards to customers’ own As Egmont Group & World Customs Organisation (2022) stated, “Customs
accounts or other entities’ accounts in the country and abroad. Most and FIUs are the best-placed authorities to identify and combat [trade-
outward transactions are headed to multiple destinations in Far East based money laundering (TBML)] nefarious and complex criminal activity.”
countries. It was also noted that the current pattern involves receiving Both play a vital role in effectively combating ML/TF and protecting the
a high value of inward remittances from several goods wholesaler integrity of the international trade system. Within said role, FIUs monitor
companies, unknown counterparties, and third parties, including unlicensed suspicious transactions and obtain and disseminate a broad spectrum
hawaladars. Furthermore, UAE legal entities are used as a ‘front’ to open of financial intelligence within different sectors at the national and
bank accounts and move money through FIs. This scheme also uses international levels. Meanwhile, customs authorities identify, intercept
different techniques of trade document fabrication, the misrepresentation and dismantle organised groups and terrorist activities that abuse the
of goods, and price manipulation. Following the establishment of new legal global trade system through their role of supervising and monitoring the
entities, corporate vehicles are abused to move money between internal movement of individuals, cash and goods across borders. Despite the global
and overseas accounts, including other legal entities’ accounts abroad. growth in using virtual assets and other non-physical forms of currency
(e.g., stored value cards), cash remains a preference for different criminal
4. Statistical review of customs data (ICP) and the UAE Remittance and terrorist groups. Similarly, currency-equivalent commodities such as
Reporting System (UAERRS) gold and precious stones are preferred due to their high liquidity and their
Money laundering (ML) is a transnational crime. As a result, criminal characteristic of being used as a means of exchange or transmitting value.
proceeds associated with ML might involve the UAE borders and its
formal and informal financial institutions to move illegal funds overseas. This is in addition to misusing the sector of money transfer remittances,
Therefore, it was important to understand and examine possible including money service business (MSB), which refers to “non-bank
connections between the movement of criminal proceeds and the UAE. financial institutions that provide certain types of financial services.”
Such a connection might be found through funds that are routed through These types of financial services include currency exchange and money
the UAE, be it physically via cross-border cash movements or electronically transmission and remittance, as is the case with the services provided by
through the abuse of FIs, including exchange houses or money value exchange houses. In different cases, ML through money remittance and
transfer systems (MVTS) like registered/unregistered hawala providers exchange houses could also involve other, different criminal activities such
(RHP/UHP), as a way in which to move funds from or to another foreign as drug and human trafficking and smuggling. In addition, a higher level
counterparty. Although domestic ML could involve transferring funds in of risk could be encountered if such a business were owned/controlled
order to complete an illegal transaction or as part of a fraudulent scheme, by criminal groups or corrupted employees who might allow criminals to
international criminal proceeds are still possibly laundered by using the access their services. The UAE’s multicultural community, wherein the
country as a ‘pass-through.’ Either way, the UAE’s borders and financial majority of the workforce are expatriates, retained the country’s position
system need to be a shield against potential international and domestic as the second-leading country in terms of total outward remittances
ML exposure. annually, following the US. Therefore, a periodic review and examination
of MSB transactions are required in order to protect the integrity of the
country’s financial services.

22 UAE Financial Intelligence Unit (UAEFIU)

 2022 HIGHLIGHTS
The below reports, together with other different sources of data, contributed to producing the four strategic analysis
reports issued in 2022.

Report Name STR/SAR DPMSR IRFI ISD ORI OSD

Total 1436 300,000 274 65 140 26

Report Report name To The 4 SA

reviewed IRFI, ISD, ORI, OSD produce Reports
STR/SAR, DPMSR

23 UAE Financial Intelligence Unit (UAEFIU)

4. Domestic Cooperation In addition, the UAEFIU was able to assist law enforcement authorities
and support their parallel financial investigations in ML cases and related
predicate offences by providing financial intelligence and analysis of data
Recognizing the importance of continuous communication and
available directly or indirectly to the UAEFIU including local databases,
information exchange, the UAEFIU has strategically engaged with key
open sources, and information from competent UAE authorities and
partners to bolster its internal database and access to national data
counterpart FIUs.
resources. Through consistent dialogue and collaboration with domestic
authorities, the UAEFIU has expanded its local data repository and
The UAEFIU takes a continuous developing approach to enhance its
analytical capacity, fostering a robust information ecosystem at the
analysis related to reactive technical reports prepared upon request of
national level.
the Public Prosecution. The UAEFIU has taken improvement measures and
effective fundamental changes to the procedures used in preparing these
The UAEFIU has also further developed the Integrated Enquiry
reports, to include analysis of information from all the available databases.
Management System (IEMS) and enhanced its functionalities, to comply
The UAEFIU has also branded out in its analysis to connect the suspects
with international standards and obtaining feedback on the PP cases,
in ML/TF cases and provide the prosecution with details of financial
where the UAEFIU provide PP with reactive technical reports based on
transactions between the related parties, which facilitated the process of
their request. The UAEFIU organised three workshops for all users with live
tracking criminal proceeds by the responsible LEA officers, and facilitate
system walkthrough that benefited 199 attendees.
requests for MLA.

24 UAE Financial Intelligence Unit (UAEFIU)

 2022 HIGHLIGHTS

41 39 17

Under Sentence - Change of

investigation Guilty jurisdiction
LEAs & IEMS
PP feedback Request
10 07
Received feedback Received 3,742 request
from the PP on the in ML and related
technical reports Cases referred Closed/ predicate offences
submitted as follow to court archived case from PP, LEA, and other

Technical Reports Team Participations

Submitted 303 technical reports Participated in 13 Joint
291 in ML and 12 in TF cases to PP Committee/Interrrogations with PP
to support their ML/TF investigation

25 UAE Financial Intelligence Unit (UAEFIU)

Policy

5. Policy Building on the experience gained by the policy function from being a
member of the national teams which drafted the main legislations related
to AML/CFT and counter proliferation (like the AML decree law and its
The policy function of the UAEFIU is mandated to maintain the policies
by-law, the cabinet decision regarding beneficial ownership, the cabinet
and procedures including the Standard Operating Procedures (SOPs) of
decision regarding local terrorist lists and UNSCRs, cash declaration
the different sections, and provide the different functions of the UAEFIU
regulations, national guide for information and financial investigations
with the legal advice on AML/CFT related issues which might arise from
and investigations in ML), the policy function is coordinating with different
the daily operations of these functions and from dealing with the local and
stakeholders in developing, updating, amending notices, circulars, guidance
international stakeholders.
and best practices related to AML/CFT on a national level.

26 UAE Financial Intelligence Unit (UAEFIU)

 2022 HIGHLIGHTS
The UAEFIU participated in reviewing and amending 20 documents during 2022, in coordination with the CBUAE, and other supervisory authorities and
stakeholders. These documents included guidelines, notices, manuals, reports, procedures, MoUs and regulations.

Type Subject Type Subject

Drafted the UAE follow up report related to FATF Legal protocol for the creation of platform for sharing
Report Guidance
Recommendation 29 operational information among FIs by PPP-SC
Drafted the internal audit task within the policy function Website Reviewed the contents of the Executive Office website
Procedures
of the UAEFIU
Guidance Guidance on Digital ID for CDD
Drafted a response to the self-assessment questionnaire
Report 14 different templates of the UAEFIU for freeze, search,
for central banks on CLS’s currency eligibility criteria Notice
and unfreeze
Regulation Drafted the CoFIU Office R&Rs and JDs
MOJ notice to lawyers regarding the REAR report on
Notice
Report The UAEFIU annual report 2021 goAML
Non-Disclosure Undertaken (NDU) to be used by the MOE notice to real estate dealers regarding the REAR
Regulation Notice
UAEFIU when dealing with external companies report on goAML
Drafted a report regarding Status of Registrar in Manual National Manual for Financial Investigations in ML
Report
Countries rated as substantial in IO5
Guidance for licensed financial institutions on the risks
Drafted a report regarding the UAEFIU functions and Guidance
Report relating to politically exposed persons
structure
Amendment of Cabinet Decision No. (10) of 2019 – AML/
Regulation
MoU Three MoUs with domestic stakeholders CFT Executive Regulations
Guidance for licensed financial institutions on the risks
Report Drafted report regarding the FIUs powers to freeze funds Guidance
relating to new payments products and services

27 UAE Financial Intelligence Unit (UAEFIU)

Outreach

6. Outreach The Real Estate Activity Report (REAR) threshold report was also
developed in collaboration between the outreach and SIS functions of
the UAEFIU and strategic partners; Ministry of Economy and Ministry
The UAEFIU continued to fulfil its mandate to conduct outreach sessions
of Justice. This reporting mechanism went live and became a mandatory
to increase the AML/CFT awareness of FIs and DNFBPs, and with other
requirement on both sectors in July 2022.
AML/CFT supervisory or law enforcement authorities.
The UAEFIU has worked closely as well with the Egmont Group training arm
The UAEFIU intensified its training and engagement efforts in 2022 by
(ECOFEL) and the United Nations Office on Drugs and Crime (UNODC)
organising and participating in more 92 training workshops, and conducting
to introduce e-learning modules on cross-border cash smuggling. The
outreach sessions and roundtable meetings with approximately 12,000
modules were launched successfully and are available globally for all
reporting entities. This resulted in better outcomes and tangible
personnel in competent authorities.
improvements in the human resource capabilities within the UAEFIU,
and better implementation of AML/CFT best practices by the reporting
entities in the country.

28 UAE Financial Intelligence Unit (UAEFIU)

 2022 HIGHLIGHTS

Training & Outreach Workshops delivered

2021 vs 2022 to other authorities
100

90

80
1
Competent Authority
70

60

50
2
DNFBPs
40

30

20 3
Financial Institutions
10

0
Training sessions attended
by UAEFIU Employee
Outreach conducted
by UAEFIU
8,023
Attendees
2021 2022

29 UAE Financial Intelligence Unit (UAEFIU)

7. Strategy The implementation of the UAEFIU strategy is ensured through the
setting of objectives and the development of the yearly operational plan.

One of the support function that is tasked with developing the UAEFIU Our five strategic objectives are:
strategy and its yearly operational plan. Strategy Function plays a critical 1. Enhancing the quality of financial intelligence at the strategic and
role to the overall internal monitoring and oversight and in liaising with operational levels
domestic competent authorities to support the implementation of the 2. Solidify the UAEFIU’s standing at the global level
UAE National Strategy on AML/CFT and the National Action Plan. 3. Strengthening the UAEFIU’s standing domestically and support to
other agencies within the national AML/CFT framework
The oversight includes a periodic review and analysis of statistics, projects
4. Strengthening the UAEFIU’s partnership and collaboration with the
or initiatives and KPIs as part of the UAEFIU operational plan or jointly with
private sector
strategic stakeholders.
5. Reinforce the UAEFIU’s organisation, resources and capabilities
The support function also looks after enhancing the overall efficiency of
the UAEFIU’s operations and the effectiveness of outcomes on an ongoing The yearly operational plan is considered as a roadmap to implement our
basis to ensure the sustainability of growth and improvement, in line with strategic objectives and priorities over time. It is also a great support and a
the national priorities and international best practices. This can only be guide for the UAEFIU sections in their day-to-day operations.
achieved through continuous oversight, monitoring and uninterrupted
On yearly basis, the UAEFIU, in conjunction with its strategic partners,
dialogue with the strategic local and international stakeholders.
assesses and evaluates the extent to which three major goals are achieved
The UAEFIU strategy is a reflection of two major pillars: via multiple channels. The results are the primary base of the next
• First is our legal mandate and functions, national policies and operational plan development:
directions, domestic and international stakeholders’ needs and • Financial intelligence disseminated by the UAEFIU is considered
expectations, as well as international best practices. useful by domestic authorities for their investigations of ML/TF
• Second is our aspirations for the future in terms of impact, offences.
effectiveness and growth. • The UAEFIU disseminates strategic intelligence to help inform the
UAE’s understanding of ML/TF risks and develop effective policies and
Our vision is “to be a leading FIU in the protection of global financial strategies to mitigate them.
integrity, peace, and security.” • The UAEFIU rapidly provides the widest range of international
cooperation to its counterparts, both spontaneously and upon
When it comes to how the UAEFIU will achieve its vision, this is clearly described request, in relation to money laundering, associate predicate offences
under the mission statement, “To produce actionable financial intelligence and terrorist financing.
for the fight against money laundering, its predicate offenses and terrorist
financing, at both the national and international levels, through the continuous As a result of the UAEFIU’s successful strategy, great results are achieved.
enhancement of subject matter expertise, methods, and technology.”

30 UAE Financial Intelligence Unit (UAEFIU)

Systems Infrastructure

8. Systems Infrastructure
One of the support functions of the UAEFIU aims to achieve the UAEFIU goal to become one of the top FIUs worldwide for its advanced technology,
utilizing innovation, optimization and standardization.

Privilege Access Management

and periodic user access review

Creating the Leading any

Business Projects related
Continuity Plan to IT changes
and Disaster within the UAEFIU
Recovery drills or with third party
for the UAEFIU vendors

Day-to-day activities Creating the Risk Based

of administering
UAEFIU owned Responsibilities Prioritization Matrix,
suggesting and updating
systems, applications, changes to the RBA and
websites (publicly facilitating the changes in
facing and intranet) the RBA through IT Team

31 UAE Financial Intelligence Unit (UAEFIU)

Main systems used by the UAEFIU: 3. Integrated Enquiry Management System (IEMS):
This system is a communication platform that the UAEFIU uses to
1. goAML: communicate with domestic stakeholders.

UAEFIU uses four modules of the goAML:

• goAML Web Interface: Used by external entities i.e. reporting

entities, supervisory bodies, law enforcement authorities and the
Executive Office for Control & Non-Proliferation
• goAML Client Application: For UAEFIU’s internal use
• goAML Business Intelligence and Data Warehousing: For the
UAEFIU to create dashboards for statistics and MIS
• goIntel: To connect the goAML Client Application with other data
sources external to it

2. FIU Hub:
The FIU Hub is an in-house built data hub. It is a user-friendly interface 4. FIU Enquiry Portal:
built over all the databases that the UAEFIU has access to. The interface This is a user-friendly interface built over the goAML database; it is
facilitates search and fetching of required data across multiple databases. intended for the use of the external stakeholders. The privileges to this
system are access driven e.g. STR information.

32 UAE Financial Intelligence Unit (UAEFIU)

 2022 HIGHLIGHTS
• The IEMS was enhanced by the following functionalities:

1. Linking cases through the system by names and case number for the same entities within the same authority, which will help them to identify the links
between subjects and will allow them to have full picture of the case
2. A Track option will be available for the requests, where LEAs will be able to see FIs’ (initial) responses before they receive the UAEFIU’s technical
reports and final response, allowing them to view and analyse FIs’ replies and documents such as account opening forms, bank statements, remittance
details, etc.
3. LEAs can re-open completed requests, keeping the same reference number but setting a different date of creation, in order to preserve the sequence
of cases
4. The system has a dropdown list for two main crimes: money laundering and terrorist financing. Under the money laundering, there is the option to
choose from 21 predicate offences which will provide accurate statistics about each one
5. Feedback feature:
• External: after the completion of all cases by the UAEFIU, LEAs have to provide the UAEFIU with feedback from their cases including how the technical
reports and FIs documents assisted them during their analysis as well as the case outcome
• Internal: feedback will benefit the UAEFIU in showing the effectiveness of the information provided in their technical reports and will help the UAEFIU
sections to conduct their analysis

33 UAE Financial Intelligence Unit (UAEFIU)

• A new goAML report was introduced, the Real Estate Activity Report, to enhance the level of intelligence disseminated to LEAs in the UAE.

2020 2021 2022 Report Name Description

Suspicious transaction with details of bank accounts/
STR STR STR Suspicious Transaction Report
statements

Suspicious activities without the bank account/statement

SAR SAR SAR Suspicious Activity Report
details

- FFR FFR Fund Freeze Report Full name match to targeted financial sanctions lists

- PNMR PNMR Partial Name Match Report Partial name match to targeted financial sanctions lists

Used for reporting cash transactions and international wire

- DPMSR DPMSR Dealers in Precious Metals and Stones Report
transfers above AED 55,000 in the DPMS sector

- HRC HRC High Risk Country Transaction Report

For transactions and activities related to FATF high risk
jurisdictions/countries
- HRCA HRCA High Risk Country Activity Report

Used for reporting cash transactions, crypto transactions

- - REAR Real Estate Activity Report (REAR) and international wire transfers above AED 55,000 in the real
estate sector

34 UAE Financial Intelligence Unit (UAEFIU)

ANNEX

ANNEX
ANNEX
ANNEX

35 UAE Financial Intelligence Unit (UAEFIU)

UAE AML/CFT LEGAL FRAMEWORK
UPDATES IN 2022
1. Cabinet Decision No. (24) of 2022 concerning the executive 2. Cabinet Decision No. (111) of 2022 concerning regulating virtual
regulations of the Decretal Federal Law No. (20) of 2018: assets and virtual assets services providers:

Following the amendment of the Decretal Federal Law No. (20) of 2018 In line with the changes in the AML By-law by including the VASPs in the
that took place during 2021 by issuing the Decretal Federal Law No. (26) of AML/CFT legal framework, Cabinet Decision No. (111) of 2022 assigned the
2021, the UAE has further enhanced its AML/CFT legal framework during Security and Commodity Authority as the supervisory authority of the
2022 by revising some of the provisions of the Cabinet Decision No. (10) VASPs on the federal level in the country.
of 2019 concerning the executive regulations of the Decretal Federal Law
No. (20) of 2018 on anti-money laundering and combating the financing The decision aimed to regulate the activities of Virtual Assets (VA) in
of terrorism and illegal organisations (the AML By-law), by issuing Cabinet the country; protect the rights of all the parties and the investors in the
Decision No. (24) of 2022. sector; ensure the effective implementation of the AML law and By-law;
and support the country’s efforts to provide an attractive investment,
A total of 22 articles have been revised and three new articles have been economic and financial environment for international companies and
introduced to the Cabinet Decision No. (24) of 2022. The changes are in line institutions working in the VA sector to provide their services in the
with the latest amendments of the FATF recommendations and consider country.
international best practices, outcomes and experiences from three years
of practical implementation of the 2019 Cabinet Decision No. (10). 3. Local Law No (4) of 2022 concerning regulating the VA in the
emirate of Dubai:
The major change to the by-law was the introduction of the VASPs to the
AML/CFT framework of the country. The VASPs are currently considered The law aimed to raise the emirate’s position as a regional and global
as Reporting Entities to the UAEFIU and has legal obligations similar to the destination in the field of VA by developing investment awareness in
FIs and DNFBPs. the sector of VA; attracting investment and companies in the field of
VA; protecting investors and dealers in VA; and providing the necessary
systems, rules and standards for organising, supervising and controlling VA
platforms, VASPs and everything related to VAs.

36 UAE Financial Intelligence Unit (UAEFIU)

International Cooperation

2022 KEY STATISTICS

This chapter outlines the UAEFIU’s most significant statistics in an 1. Total Number of IRIs from Counterpart FIUs from 2020 to 2022
expansion of data presented in the Overview of 2022 Figures (page 8).
IRIs received from counterpart FIUs
1. International Cooperation 01/01/2020 to 31/12/2022

900

800
In respect of cooperation with counterpart FIUs, the following are the main 782
700
involved tasks: 727
600

500 568
1. Incoming Request for Information (IRI);
2. Outgoing Request for Information (ORI); 400
3. Incoming Spontaneous Dissemination (ISD); and 300
4. Outgoing Spontaneous Dissemination (OSD). 200

100
The next tables and graphs are related to some of the UAEFIU efforts in
0
the area of international cooperation during 2022.
2020 2021 2022

37 UAE Financial Intelligence Unit (UAEFIU)

2. Regions UAEFIU received Requests for Information (IRFIs) from in 3. Total Number of OSDs to Counterpart FIUs from 2020 to 2022
2022
OSDs sent to Counterpart FIUs
Region No. of IRFIs 01/01/2020 to 31/12/2022

Europe 43%
Asia 41%
North America 8%
194
Africa 7%
South America 0.9%
Oceania 0.1% 100
Grand Total 100%

No. of IRFIs
7
01/01/2020 to 31/12/2022 2020 2021 2022

0.9% 0.1%

7% Europe
8% Asia

43% North America

41% Africa

South America

Oceania

38 UAE Financial Intelligence Unit (UAEFIU)

4. Regions UAEFIU sent ORFIs to in 2022 5. ORFIs to counterpart FIUs) by offence/suspicion

Region Volume of ORIs Offence / Suspicion % of ORFI

Asia 49% Corruption and Bribery 1%

Europe 34% Drug trafficking 7%

Foreign predicate offences 4%
North America 8%
Fraud 9%
Africa 8% Hawala Providers 18%
South America 1% Illicit trafficking in stolen and other goods 3%
Grand Total 100% ML- other offences (unexplained transfers) 1%
Money Laundering- other offences (
11%
Donations, unexplained transfers)
No. of ORFIs Professional (third-party) Money Laundering 9%
Smuggling (Including in relation to customs
1%
and excise duties and taxes)
1% Subject to adverse media 1%
Tax crimes 16%
8% Asia
Theft and robbery 1%
8% Europe Trade-based money laundering (TBML) 18%
49% North America Grand Total 100%

34% Africa

South America
No. of ORFIs
1%
Corruption and Bribery
Drug trafficking
1% 7%
18% 4% Foreign predicate offences
Fraud
9% Hawala Providers
Illicit trafficking in stolen and other goods
ML- other offences (unexplained transfers)
Money Laundering- other offences
16% 18% (Donations, unexplained transfers)
Professional (third-party) Money Laundering
Smuggling (Including in relation to
9% 11% 3% customs and excise duties and taxes)
1% Subject to adverse media
Tax crimes
39 UAE Financial Intelligence Unit (UAEFIU)
1% 1% Theft and robbery
Trade-based money laundering (TBML)
2. Operational Analysis 1. No. of Cases (incl. Reports) Disseminated to the LEAs

Number of Disseminations to LEA

2021 Vs. 2022
In respect of operational analysis of STRs, SARs, and other reports
received from Reporting Entities (RE), including FIs, DNFBPs, and VASPs,
the following are the main involved tasks:

1. Receiving reports from REs;

212
2. Reviewing and prioritising;
145
3. Collecting data and analysing; and
4. Disseminating cases to LEAs.

The below tables and graphs are related to some of the UAEFIU efforts in
the area of operational analysis during 2022.
2021 2022

Number of Reports Included in the Disseminations

2021 2022

702 510 1084 739

STRs/SARs Others

40 UAE Financial Intelligence Unit (UAEFIU)

The volume of cases disseminated to the LEAs in 2022 rose by 3. Total Number of Reports received by Sector
approximately 46%, compared to the 2021 figure. A similar increase
occurred in the types of cases analysed across a wide range of typologies, In 2022, the UAEFIU received 33,459 STRs and 5,453 SARs (total of 38,912
these include the following: reports), of which FIs submitted 95% (37,117 reports). DNFBPs filed 1,076
reports (3%), in addition to 719 reports from VASPs and others (2%).
2. Typologies related to cases analysed during 2022
The below graphs illustrate the change in volume of reports filed by each
Count of sector to the UAEFIU during 2022 in comparison to 2021.
Typologies Percentage
Dissemination
Professional 3rd party ML or networks Financial DNFBPs VASPs
56 26.42%
of 3rd party laundering Institutions 2021 Vs. 2022 & Others
Fraudulent transfer (domestic and 2021 Vs. 2022 2021 Vs. 2022
30 14.15%
international fraud recall)
Trade-based ML 28 13.21% 37,117

Laundering the proceeds of drug/

27 12.74% 20,919
human trafficking
Case involved complex ML
methodologies and/or businesses/ 1,076
26 12.26% 719
companies in higher risk sectors, cash,
366 422
PMS smuggling and dealers in PMS.
The laundering in UAE of proceeds from
foreign predicate offences (including 12 5.66% 2021 2022 2021 2022 2021 2022
direct and indirect tax crimes)
ML through hawala activities
9 4.25% Overall, there was a 79% increase in the total reports received in 2022.
(unlicensed)
Linked to sanctioned parties/countries 9 4.25% DNFBPs filling (including real estate agents and brokers, DPMS, lawyers
Subject to adverse media 3 1.42% and notaries, accounts and auditors, and trusts and CSPs) surged by
Possible terrorist financing 11 5.19% around 200%.
Dual use products 1 0.47%
The reports received from VASPs sector and supervisory authorities also
Grand total 212 100% increased by 70% during 2022.

41 UAE Financial Intelligence Unit (UAEFIU)

3. Domestic Cooperation

In 2022, UAEFIU received 3,742 requests for specific financial or non-financial information – 868 on juridical persons, 2,727 were on natural persons and 147
on bank account numbers. The tables below illustrate the requests received from relevant stakeholders.

Request Type Total 2022

Account review and analysis Report 122
Database - STR Arabic rephrasing 7
Database - STR Search 780
Joint Committee/Interrogations 13
Requests to Foreign FIU 12
Search and Freeze to all FIS 423
Search and Freeze to specific FIS 79
Search to all FIS 1,901
Search to specific FIS 304
Unfreeze to all FIS 71
Unfreeze to specific FIS 30
Grand Total 3,742

42 UAE Financial Intelligence Unit (UAEFIU)

The second table represents the count of requests received from LEAs based on the case category.

Subject of Inquiry
Case Category Juridical Person Natural Person Account No. Total
Any proceeds resulting from a felony or misdemeanor 17 26 1 44
Drug trading 2 29 18 49
Breach of trust 1 5 6
Corruption and bribery 107 64 1 172
Counterfeiting currency 1 10 11
Extortion 1 1
Forgery 3 12 1 16
Fraud 115 241 44 400
Fraud cybercrime 3 89 2 94
Gambling 1 1
General inquiry 5 5
Illicit trafficking in narcotic drugs and 1 1
Illicit trafficking in narcotic drugs and psychotropic substances 29 190 12 231
Illicit trafficking in stolen and other goods 8 6 14
Money laundering 512 1,793 62 2,367
Murder, grievous bodily injury 9 9
Participation in an organised criminal group and racketeering 1 1
Proliferation 2 2
Robbery or theft 2 36 2 40
Smuggling; (including in relation to customs and excise duties and taxes) 3 54 57
Tax crimes (related to direct taxes and indirect taxes) 14 7 21
Terrorism financing 9 27 36
Terrorism, including terrorist financing 32 114 146
Trafficking in human beings and migrant smuggling 5 5
Illicit money transfer 2 7 4 13
Grand total 868 2,727 147 3,742

43 UAE Financial Intelligence Unit (UAEFIU)

4. List of Risk Indicators

I. Fraud Crimes, Trends and Typologies Report

• A customer submitting documents suspected to contain any materially false, fictitious, or fraudulent statement or entry.
• A customer knowingly falsifies, conceals, or covers up via any trick or scheme a material fact or makes any materially false statement or
representation.
• Discrepancies observed between reported facts, observed data, and/or supporting documentation.
• Inadequate or apparently altered supporting documentation (such as, alterations to any vital information, scraps, spelling mistakes, etc.).
• Supporting documents that contains vendor receipts and/or other supporting documents that appear to be altered (obvious white-out areas,
cuttings, deletions).
• ‘Funds recall requests’ received from different remitting banks on the same beneficiary.
• Funds received via wire transfers (international or local) from unrelated parties, followed by immediate withdrawals or outward remittances.
• Incoming funds transfer followed by ‘Funds recall request’ from the remitting bank.
• Frequent incoming funds transfers from unrelated parties to a newly opened account(s).
• Insufficient justifications obtained from the account holder on the received funds, or a customer that clearly unaware of the purpose and source of
funds received in the account.
• Accounts opened for ‘Salary’ purpose especially individuals as low-income workers with no actual salary income witnessed in the account, instead
the account receiving multiple remittances or deposits from unrelated parties.
Other ‘Red flag’ indicators (Financial/Behavioral):
• Unusual transactions or inter-account transfers (including relevantly small amounts).
• Rising costs with no explanation or that are not commensurate with an increase in revenue.
• Employees who appear to make a greater than normal number of mistakes, especially where these lead to financial loss through cash or account
transactions.
• Employees who are subject to complaints and/or tend to break the rules and who also request details about proposed internal audit scopes or
inspections.

44 UAE Financial Intelligence Unit (UAEFIU)

 II. Report on Dealers in Precious Metals and Stones (DPMS)
• DPMS entity has a peculiar structure that is unreasonable and complex, e.g., there is potential involvement of shell companies, a parent or subsidiary
of an offshore company, in which the UBO is difficult to identify or cannot be identified (whose main purpose is to hide the UBO and/or disguise fund
transfers as a capital transfer or normal business transaction).
• DPMS set up as a front company (presence of real business activity; use to commingle legitimate and illegitimate funds, mainly used effectively in
cash-intensive businesses).
• Large and complex transactional behaviors for newly established entities as DPMS.
• Unnecessarily maintaining multiple bank accounts for the same entity (DPMS), or opening accounts under the names of employees.
• DPMS entity or its representatives are transacting outside of the normal monetary system, or are making excessive use of cash transactions.
• DPMS or its representatives are using gold as a medium of exchange.
• The circulation of funds between multiple DPMS accounts, or between ‘unrelated’ parties which are in different lines of business that might also be
suspected of being ‘shell companies’ (no real business activity; incorporated for ML purposes exclusively).
• The transaction structure appears to be unnecessarily layered and designed to obscure the true origin of funds.
• DPMS entity’s owners, shareholders, or authorized signatories, or any of its counterparties, have been the subject of adverse news from a trusted
media source.
• DPMS or any of its controlling persons, or its affiliates, have been found to be associated with a high-risk jurisdiction.
• DPMS entity that is heavily engaged in cross-border cash movement.
• DPMS entity repeatedly depositing large cash amounts in an account, or exchanging foreign currencies, which is supported by ‘cash declaration
forms,’ also known as DRIC forms (Declaration Regarding Importation of Cash).
• DPMS or its representatives fail to provide a ‘customs declaration’ in relation to a local/foreign currency cash deposit related to buying/selling
precious stones.
• DPMS entity engages in transactions and shipping routes or methods that are inconsistent with standard business practices.
• Contracts, invoices, or other trade documents provided by a DPMS have vague or missing descriptions, appear to be counterfeit (including false or
misleading information), include a resubmission of previously rejected documents, or are frequently modified or amended.
• DPMS entity or any of its counterparties appear to import precious metals and stones that originate from a country in which there is limited
production or no mines at all.
• Deposits or transfers are received in a DPMS account followed by the immediate transfer of similar amounts to another jurisdiction.

45 UAE Financial Intelligence Unit (UAEFIU)

 • DPMS entity and its associates, or multiple individuals (external parties), excessively conduct foreign exchange transactions (FOREX) without any
business rationale.
• Payment for imported PMS made by an entity other than the consignee for no clear business reason, e.g., by a shell or front company not involved in
a trade transaction.
• Cash deposits or other transactions of a DPMS entity (or its representatives) are consistently just below the relevant reporting thresholds
(transactions conducted by multiple individuals to avoid reporting requirements).
• Transactions in a DPMS account(s) are seemingly of a pass-through nature, with funds directly debited via wire transfers leaving a low balance in an
account.
• DPMS entity(s) excessively obtain loans or credit facilities, which are settled before the due date through cash or cheque repayments.
• DPMS entity(s) transfer payments amongst each other, which are related to 'borrowings' or 'loans' that is referred to as 'back-to-back' or 'loan-back'.

III. Far East Typology Patterns and Schemes

• A rapid movement of funds via inward wires from multiple counterparties, internal transfers, cash and cheque deposits, or customers’ own external
accounts, followed by outward wires toward other corporate or customers’ own accounts in the UAE or in Far East countries.
• A new established legal entity (licensed for trade activities, as mentioned previously) with a significant difference between the reported turnover in
the KYC and the actual turnover.
• A change in name and ownership of an entity following its establishment.
• UBOs who are most likely in their late twenties or early thirties and from, but are not limited to, South Asian countries.
• No rationale behind a large volume of inward and outward transactions from/to the identified Far East route over a short span of time (on the same
day or on consecutive days, or over a few months).
• Inconsistency between account activities and turnover and the profile of the customer and the nature of the business.
• Employing dormant accounts or accounts with no observed business transactions until a sudden surge in the flow of funds by means of the Far East
route.
• No actual business activity or operational expenses being observed in the company account.
• Corporate accounts being opened in different currencies to receive or send money while left with a low or nil balance.
• Difficulty in identifying or establishing the relationship between the customer and trading counterparties or ultimate buyers.
• Phantom shipments including trade document fabrication, the misrepresentation of goods and services, and price manipulation.

46 UAE Financial Intelligence Unit (UAEFIU)

 • Customer failure or reluctance to provide a complete set of documents to substantiate account activity (such as the shipment of goods, valid bills of
lading, clear trading settlement arrangements, custom clearance certificate, etc.).
• The business background of a UBO or the nature of a business cannot be validated in the public domain (e.g., no website for the business).
• Counterparties having a different line of business and there being difficulty in establishing the nature of customers’ business.
• Funds being layered between accounts of mutual counterparties.
• The customer having been found to be transacting (internally/externally) with previously reported entities where the relationship had been
terminated due to various ML concerns.
• The supplier of the customer being previously reported due to ML concerns.
• High Value of local remittances and clearing cheques received from (registered) hawaladars/MSB where the information relating to ultimate source
of funds could not be established.
• Potential link to using unregistered hawaladars (I.e., involvement of third parties while the ultimate source of funds or remitter details are not known).
• Conducting business with or through Iran Nexus and OFAC-sanctioned entities.

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 GLOSSARY
GLOSSARY
GLOSSARY

48 UAE Financial Intelligence Unit (UAEFIU)

Term Description Term Description
Anti-Money Laundering / Countering Financing of ML/TF Money Laundering / Terrorist Financing
AML/CFT
Terrorism MLA Mutual Legal Assistant
AMLSCU Anti-Money Laundering and Suspicious Cases Unit MOE Ministry of Economy
Decretal Federal Law No. (20) of 2018 and its MOJ Ministry of Justice
AML Law
amendments
MoU Memorandum of Understanding
AML By-law Cabinet Decision No. (10) of 2019 and its amendments
MSB Money Services Business
CoFIU Chief of Financial Intelligence Unit
National Committee for Anti Money Laundering and
CBUAE The Central Bank of the UAE
NAMLCFTC Combating the Financing of Terrorism and Financing of
Combatting the Financing of Terrorism and Illegal
CFT Illegal Organizations
Organisations
ORI Outward Request for Information
CSPs Company Service Providers
OSD Outward Spontaneous Dissemination
DNFBPs Designated Non-Financial Businesses and Professions
DPMS Dealers in Precious Metals and Stones PF Proliferation Financing
DPMSR Dealers in Precious Metals and Stones Report PNMR Partial Name Match Report
Egmont Egmont Group of Financial Intelligence PP Public Prosecution
FATF Financial Action Task Force RE Reporting Entities
FFR Funds Freeze Report RFI Request For Information without Transactions
FIs Financial Institutions RFIT Request for Information with Transactions
FIU Financial Intelligence Unit RFR Reason for Reporting
FFIU Foreign FIU SAR Suspicious Activity Report
The Financial Intelligence Unit's Online Reporting
goAML SOP Standard Operating Procedure
Application
SS State Security
HRC High Risk Country Transaction Report
STR Suspicious Transaction Report
HRCA High Risk Country Activity Report
IDR Inward Dissemination Request TBML Trade-Based Money Laundering
IEMS Integrated Enquiry Management System TF Terrorism Financing
IRI Inward Request for Information UAERRS UAE Remittance Reporting System
ISD Inward Spontaneous Dissemination UNODC United Nations Office on Drugs and Crime
KPI Key Performance Indicator VA Virtual Assets
LEAs Law Enforcement Authorities VASP Virtual Assets Services Provider
49 UAE Financial Intelligence Unit (UAEFIU)