2. Understanding Risks
The FATF's Mutual Evaluation Report of the UAE issued in April 2020 stated that the two sectors of real estate and precious metals and stones are weighted as highly important in terms of risk and materiality in the UAE. While the nature and extent of the risk posed by the two sectors to the LFIs providing them with accounts and other financial services is different, they do share common characteristics that LFIs should recognize and take into account:
• Attractiveness to illicit finance. The real estate and precious metals and stones sectors are important parts of the UAE's economy, and each provides important, legitimate goods and services to the UAE population and global trading partners. Nevertheless, experience shows that these sectors offer services that are particularly attractive to illicit actors.
• Facilitation of the international movement of value. Despite their different natures, both sectors allow individuals to move large values across international borders, sometimes with only minimal involvement from the formal financial system. For example, a courier carrying a valuable diamond can move millions of AED of value simply by taking a short international flight. In addition, the real estate and precious metals and stones sectors allow individuals to hold value in a form that retains value over time (such as gold or real property) without having to maintain an account in the formal financial system. These facilities are useful to many legitimate businesses, but are also highly sought-after by illicit actors.
• Varying regulatory regimes. The extent and nature of regulation on these sectors varies widely between jurisdictions. In some jurisdictions, participants such as dealers in precious metals and stones (DPMS) and real estate agents and brokers are required to be licensed or registered, and to comply with AML/CFT requirements that are similar to those imposed on LFIs. These include, at a minimum, the requirement to perform CDD on customers and to report suspicious transactions. Despite the existence of these requirements, however, sector participants are in many cases not closely supervised or monitored for compliance. Their understanding of their risk and of their compliance obligations may not be well-developed or accurate. In other jurisdictions, there are limited or no obligations placed on these actors, and they may not have any understanding of how they can be abused by illicit actors, or the steps they should take to protect themselves.
2.1 Understanding and Assessing Risks Related to DPMS
Dealers in precious metals and stones (DPMS) play a significant role in the economy of the UAE. DPMS engage in a wide range of activities related to precious metals and stones, from production to trading, establishing the UAE as an important regional hub for this sector. The Dubai Multi Commodities Centre specializes in providing services to precious metal dealers and exchanges, and a significant volume of transactions also goes through the Jebel Ali Free Zone. A significant amount of activity also occurs in the Dubai Gold Souk.
Nonetheless, the precious metals and stones sector offers opportunities for criminals seeking to conceal, transfer, and/or invest their illicit proceeds. Like cash, precious metals and stones offer high value by weight, are difficult to trace and identify, and retain their value over time. DPMS, if they do not apply effective preventive measures, could be vulnerable to abuse by illicit actors engaged in laundering the proceeds of crime, financing of terrorism, arms trafficking, sanctions evasion, and other illicit activities.
2.1.1 Risks of Precious Metals and Stones
The characteristics of precious metals and stones make them uniquely appropriate as media to store, transfer, and exchange value:
i. Precious metals and stones are generally compact, durable, odourless, and of high value.
ii. Certain metals and stones (e.g., gold or diamond) are widely accepted as a method of exchange or currency.
iii. Precious metals and stones retain their value over time, and have roughly the same value all over the world.
In addition to these properties, precious metals and stones have characteristics that make them particularly attractive to criminals seeking to launder funds and others engaged in illicit behaviour:
i. Differentiating precious metals and stones often requires laboratory techniques, so it can be difficult or impossible to track their movement;
ii. Precious metals and stones can be transformed (through re-cutting or recycling) into different objects while retaining their value, interrupting known custody and transfer chains;
iii. Purchase, sale, and exchange of precious metals and stones often takes place outside the formal financial system.
For these reasons, DPMS may be targeted by illicit actors seeking to abuse their services and exploit the advantages of precious metals and stones. Although the majority of transactions involving DPMS are legal, these businesses may trade in items that could be the proceeds of crime, purchased with the proceeds of crime, and/or used to launder the proceeds of crime, unknowingly or complicitly.
Because they are themselves at high risk of abuse, DPMS pose a risk to LFIs. Complicit DPMS may knowingly partake in illicit activities and may in turn use their business relationships with LFIs to launder the proceeds of crime or carry out other illicit activity. Even DPMS that are not knowingly involved in illicit activities may use their accounts with an LFI to deal in the proceeds of crime. For example, a DPMS may wire payment for illegally mined gold to the entity responsible for mining and processing the gold.
Gold as a High-Risk Medium of ExchangeGold is easy to exchange and transfer, and may provide anonymity when processing transactions, as it is difficult to trace. It also has a universal price standard, a relatively stable market for investment, and may be used as a currency. Gold dealers may provide specific services to their clients, such as metal accounts, for storage or for investment properties. This may enable criminals to move gold under the guise of legitimate business.
2.1.2 Features of DPMS that Increase Risk
Not all DPMS pose equal risk. A DPMS is likely to be considered higher risk when it provides products or services that are attractive to illicit actors, has operations in high-risk jurisdictions, or does not apply appropriate anti-money laundering/combatting the financing of terrorism (AML/CFT) controls.
2.1.2.1 Regulatory Environment
In many jurisdictions, DPMS are not required to comply with requirements related to identification of customers and reporting suspicious activities. In other jurisdictions, these requirements are nominally in place, but DPMS are not subject to effective supervision and enforcement. Even in a jurisdiction that imposes and enforces such requirements, they frequently apply only to DPMS that engage in cash transactions above a certain value threshold. Where DPMS are unregulated or under-regulated, they are unlikely to be taking effective measures to protect themselves from abuse.
In contrast, an effective AML/CFT framework and supervisory regime for DPMS can protect DPMS and LFIs that serve them by effectively imposing AML/CFT requirements and by detecting, deterring, and prosecuting ML/TF crimes. It is important to note that, like LFIs, certain DPMS in the UAE are required to comply with all requirements of AML-CFT Decision, including the requirement to perform Customer Due Diligence (CDD) and report suspicious transactions (see section 2.1.4).
2.1.2.2 Products, Services, and Delivery Channels
Products, services, and delivery channels that facilitate the rapid, efficient, anonymous movement of value on a large scale will be more attractive to illicit actors and may put a DPMS at a higher risk of abuse. Such products, services, and delivery channels may include:
• Products (such as bullion and uncut stones) that are particularly hard to trace, retain or even increase in value despite being transformed into new forms (melted down, re-cut, etc.), and offer high value by weight. • Services, such as metal accounts, that allow customers to rapidly purchase and sell precious metals or stones. • Delivery channels that allow transactions to be carried out quickly and anonymously, such as accepting cash or virtual assets and conducting transactions online or through intermediaries.
2.1.2.3 Customer Base
The types of customers that a DPMS serves can also impact risk. For example, a DPMS that primarily deals with PEPs may be higher risk than one that serves a lower-profile clientele.
2.1.2.4 Geography
DPMS may be based, or may trade internationally, in jurisdictions that are higher risk for money laundering, the financing of terrorism, and the financing of proliferation. Such DPMS may pose heightened risk to LFIs. Higher-risk jurisdictions may be characterized by:
• A low level of government oversight and regulation of the precious metal and stone value chain;
• Low economic and political stability;
• High use of the informal banking system;
• High levels of corruption;
• The presence of terrorist and other non-state armed groups;
• Weak border control measures; and/or
• Sanctions and embargoes
Where a DPMS is based in a high-risk jurisdiction, LFIs are required by AML-CFT Decision to perform Enhanced Due Diligence.
2.1.3 Typologies
Precious metals and stones may be involved in a wide variety of illicit finance schemes. The following are some of the most common.
• Illegal mining or mining supported by the proceeds of crime. In jurisdictions where precious metals or stones are mined, illicit actors may operate small-scale ‘artisanal' mines without receiving a license or paying taxes to the state. The products of these mines are then exported to a refining or cutting hub for processing into saleable goods, like gold bullion and cut stones.
In many cases, criminal organizations control a mine or a network of small-scale miners. They may invest the proceeds of other illegal activities, such as drug trafficking, into the illegal mines and take the majority share of the resulting production as a return on investment. When the resulting precious metals or stones are processed, the criminal organization can sell them on world markets. The proceeds fund further illicit activities and may also support terrorism.
Example: Trading in gold to legitimise the proceeds of drug traffickingA criminal organisation in Country X was buying gold from various precious metals retailers using illicit proceeds from narcotics sales. The gold was then sold to a precious metals broker who then sold it to other businesses. The proceeds of the sale were then wired to a third party outside of Country X with links to the drug trafficking organization, thus completing the money laundering cycle.
• Use of precious metals and stones in sanctions evasion. The tradable nature, liquidity, wide availability, and anonymity of precious metals and stones has made them popular with individuals, organizations, and governments seeking to evade sanctions imposed by the United Nations or other jurisdictions. This activity may involve mining precious metals or stones under the control of the sanctioned person; the resulting products are then injected into legal trade using front companies and complicit DPMS, earning money for the sanctioned group. Or sanctioned actors may use precious metals and stones to disrupt a transaction chain involving the formal financial system and thus hide their interest in a transaction.
Example: Large-scale sanctions evasion using precious metalsAccording to Country A's federal indictments, a government sanctioned by Country A used front companies and complicit financial institutions to buy large quantities of gold in Country B. The gold was supposedly exported to the purchasing country, but was in fact moved by courier to the UAE, where it was sold in exchange for cash (U.S. dollars and euros). The cash was deposited with LFIs in the UAE under the names of front companies, and was made available to the sanctioned government to use in proliferation activities.
• Evasion of duties on precious metals and stones. Precious metals and stones are often the subject of heavy customs duties and other taxes. As a result, illicit actors will frequently seek to smuggle these goods from high-tax to low-tax jurisdictions, or may declare artificially low values for the goods by misrepresenting their quality or purity.
• Trade-based money laundering (TBML). The value of precious metals and stones varies highly based on their quality and purity, features which may not be apparent to the naked eye. In addition, the value of certain precious stones, particularly diamonds, can differ for different non-industry customers based on their personal preferences. This makes precious metals and stones particularly vulnerable to TBML, in which illicit actors use supposedly or actually licit trade to hide illicit finance. This can take a variety of forms:
o Trading the same goods—often precious stones—repeatedly between co-conspirators to justify funds transfers between members of a criminal network, or between companies owned by the same individual(s). In these schemes, a single precious stone may be repeatedly sold between members of the network, or a single stone may be sold to multiple “purchasers” at the same time, each time with a different description.
o Inflation or deflation of the value of traded stones to provide justification for cross-border transfers. A merchant may sell low-value precious metals or stones to a purchaser, but invoice for higher-quality goods and thus a higher sum. The purchaser pays the full invoice price, justifying the transaction to financial institutions, and also receives illicit goods such as drugs or smuggled items.
• Use of precious metals and stones as security for fraudulent loans. In a typology that is often related to TBML, precious metals or stones may be repeatedly sold or falsely valued between members of a network in order to justify loans and other forms of financing.
Example: Over-Valuation to Justify Illicit TransfersMr. A, a licensed DPMS, entered Country X numerous times, each time declaring that he was carrying valuable precious stones. He was in fact carrying gems that were lower value than the ones he declared. He then substituted the lower value gems for higher value gems that were already in Country X and presented them for inspection and clearance at an official diamond exchange. Through these methods, Mr. A obtained validated official importation statements for multiple importations of high-value stones which did not actually take place. He used these statements, together with fake invoices, to facilitate international foreign currency transfers to entities abroad in the guise of payment for the imported goods. He ordered these transactions both for himself and on behalf of other DPMS wanting to receive funds abroad without having to face scrutiny by financial institutions and public authorities.
2.1.4 Regulation and Supervision of DPMS in the UAE
DPMS that qualify as Designated Nonfinancial Businesses and Professions (DNFBPs) are subject to AML/CFT requirements that are substantially the same as those imposed on LFIs, including the requirement to identify customers, to report suspicious transactions, and to perform a risk assessment. Under Article 3 of AML-CFT Decision, DPMS qualify as DNFBPs only if they are “carrying out any single monetary transaction or several transactions that appear to be interrelated or equal to more than AED 55,000". A DPMS that does not engage in such transactions is not required to take any preventive measures. Although cash transactions are certainly high risk, LFIs should be aware that the fact that a DPMS does not qualify as a DNFBP does not mean that it is low-risk. All DPMS, regardless of whether they qualify as DNFBPs, must have a commercial license to operate legally in the UAE. The Ministry of Economy is also responsible for identifying and classifying DPMS as DNFBPs; LFIs are not required to make this determination. But LFIs should discover, through the CDD process, whether their customer has been classified as a DNFBP by the Ministry of Economy.
Obliged DPMS are supervised for compliance by the Ministry of Economy, which has issued guidelines for supervised entities describing their AML/CFT compliance obligations.2
2 Available at https://www.economy.gov.ae/english/Pages/AML.aspx.
2.2 Understanding and Assessing Risks Related to the Real Estate Sector
The real estate sector is an important part of the UAE's economy, responsible for as much as 20 percent of Gross Domestic Product (GDP). The UAE real estate sector is diverse, encompassing construction and development, commercial real estate sales, and a wide variety of residential real estate, from apartments to luxury villas. A large number of professional real estate agents and brokers—over 11,500—support this sector.
Most transactions within the sector are legitimate. Nevertheless, LFIs should be aware that the real estate sector offers opportunities for criminals seeking to conceal, transfer, and/or invest their illicit proceeds. The real estate market is a fairly liquid market in which assets generally retain stable values over time. Real estate transactions are generally large and offer criminals the opportunity to launder large values in a single transaction. And unlike other stores of value, such as cash or precious metals and stones, real estate can be enjoyed or can earn income while it is in the owner's possession.
2.2.1 Risks of the Real Estate Sector
The real estate sector is attractive to criminals and other illicit actors for many of the same reasons that it is popular with legitimate investors: real estate is a fairly liquid market, with assets that generally maintain or appreciate in value over time. Like certain forms of gold and precious metals, and unlike stores of value such as currency and stocks, real estate can be enjoyed by the owner. Indeed, the purchase of luxury real estate may in fact be the ultimate goal of the money laundering process.
In addition, certain characteristics of the sector, while not in themselves illicit or undesirable, offer advantages for those seeking to launder funds and to move large values between individuals and across borders in a relatively short time:
• The sale or purchase of real estate is a normal, everyday transaction, and offers a simple, convenient explanation for the source of funds in a large transaction.
• Real estate transactions are typically high-value, allowing illicit actors to launder large sums in a single transaction.
• Real estate transactions of all kinds often take place between shell companies created for the sole purpose of owning real property. This practice makes it difficult to identity the true owner of the property. In addition, the ubiquity of this practice makes it difficult to distinguish licit from illicit transactions.
• The price of real estate is not fixed and is somewhat subjective, allowing illicit actors to inflate or deflate sales or purchase prices to better suit to their schemes.
• Real estate is frequently sold and re-sold in fairly quick succession, making it less suspicious when a criminal engages in similar behaviors in order to layer laundered funds.
• In some jurisdictions, the ownership of real estate gives the owners access to residency rights. Illicit actors may take advantage of these rights to expand their criminal networks to new jurisdictions, to escape criminal investigation in their home countries, and to hold assets offshore without alerting their home authorities.
The real estate sector may be abused at any stage of the laundering process
• Placement: A criminal may invest illicit funds into the sector through an initial purchase in cash. • Layering: A criminal may conceal the true origin of illicit funds by selling and purchasing a number of properties, extending the distance between current assets and the original placement of the funds. • Integration: A criminal may sell a property and invest the funds in stocks, using the paperwork from the sale to demonstrate an apparently acceptable source of funds.
2.2.2 Features of the Real Estate Sector that Increase Risk
Certain features of the real estate sector in different jurisdictions can increase the attractiveness of the sector to illicit actors. Although these features are not in themselves negative or undesirable, they have the effect of increasing the ease with which illicit actors can use the sector to launder funds.
• Varying regulation and supervision of real estate professionals. Real estate agents and brokers are well placed both to detect and to collude in suspicious transactions. Agents and brokers are able to observe suspicious client behaviour, as well as aspects of a transaction that do not have a reasonable explanation. Conversely, complicit real estate professionals may advise a client on how to avoid scrutiny from LFIs and government authorities. This risk is increased in jurisdictions where agents handle client funds, such as in escrow or trust accounts.
Because of the special role played by real estate professionals, the FATF Recommendations require that many such professionals be regulated and supervised, with AML/CFT obligations like those imposed on financial institutions. Where these obligations are not imposed and enforced, and where real estate professionals are not monitored for their compliance, the sector may be higher risk.
• Widespread use of cash. In certain jurisdictions, real estate transactions are frequently executed entirely or partially in cash. This allows a transaction to take place without involving the formal financial system. In addition, criminal activities often produce high volumes of cash, and placement of cash derived through illegal activities is often the first step in the money laundering process. Even if a particular transaction is executed through bank cheque or other similar means, if the property was purchased for cash in the recent past it can be difficult or impossible to fully understand the chain of ownership and thus to identify whether a transaction is part of the money laundering process (e.g., the property was purchased in cash by A, sold to B to launder the original purchase funds, and is now being re-sold to A).
• Lack of transparency on beneficial owners. As discussed above, illicit actors, like many purchasers of real estate, often engage in transactions using shell companies, and engage intermediaries such as law firms to represent them and obscure their interest in a property transaction. Where a jurisdiction does not collect beneficial ownership information for such companies or for real property in general, and permits foreign companies to own real estate, it increases the likelihood that law enforcement and LFIs will not be able to identify the individuals behind a purchase or sale.
• Openness to foreign purchasers. A real estate sector that is entirely open to non-residents and non-citizens is likely to be more liquid than a closed sector. In addition, an open sector is exposed to illicit funds generated all over the world. Jurisdictions that offer residency or citizenship rights to foreign purchasers of domestic real estate may be particularly attractive to foreign illicit actors.
• High liquidity and rising prices. Illicit actors, like licit investors, want assurance that they will be able to sell an investment property for an amount that recoups their investment or offers a profit. Although they may be willing to tolerate a modest loss on the investment as the cost of money laundering, they may be more likely than most purchasers to seek to ‘flip' properties, buying and selling them in quick succession. A highly liquid market facilitates flipping and increases the likelihood that the sale price will meet or exceed the purchase price. In addition, rising prices and a ‘hot' market make it easier to disguise certain typologies, such as making small renovations to a property and then reselling it to an associate for a steeply increased price. The difference between the purchase price and the market value is then secretly refunded to the buyer in cash.
2.2.3 Typologies
Illicit actors may use a wide variety of strategies to launder the proceeds of crime through the real estate sector. Many of these strategies are not specific to the real estate sector and appear in a variety of contexts.
The following are some of the most common.
• Placement of cash. There are a variety of ways that the real estate sector can be used to place the cash proceeds of crime.
o Perhaps the simplest is purchasing a property in cash and then selling it, with the purchase price paid via wire or bank cheque. The criminal can identify a clear source of funds for the funds received, and can proceed to layer them using other techniques.
o This basic typology is subject to a number of variations. A property owner may pay for renovations in cash that represents the proceeds of crime, thus increasing the property's value. When the property is sold, the purchase price will include the value of illicit funds spent on renovations.
o An illicit actor may receive a bank loan to purchase the property, and then pay the loan back early in cash, or make payments in cash.
o Real estate investments, such as rental properties, may also be cash-intensive businesses. In jurisdictions where it is common to pay rent in cash, these properties can be used to commingle licit with illicit funds.
• Use of shell companies or other legal entities to obscure ownership. As discussed above, the use of shell companies—legal persons with no operations or employees—to hold real property is a common feature of real estate sectors all over the world. This practice facilitates investment and business (e.g. owning a shopping mall and collecting rent from tenants) and also preserves privacy (e.g. a prominent individual purchasing a home using a shell company to avoid her address becoming public knowledge).
Despite the legitimate uses of this technique, however, it can also be used to hide ownership when the true owner is an individual who does not want to be linked to the purchase. This may include Politically Exposed Persons (PEPs) who are purchasing properties that are inconsistent with their known sources of wealth; individuals who have past convictions for proceeds-generating offenses or are associated with negative news; and sanctioned individuals.
In place of or in addition to shell companies, illicit actors may use complex ownership structures, legal arrangements, and nominee arrangements to conceal their ownership interest in a real estate transaction. Please see the CBUAE's Guidance for Licensed Financial Institutions providing services to Legal Persons and Arrangements3 for more information on the risks of legal persons and arrangements.
• Use of intermediaries to obscure ownership. Similarly, individuals who wish to hide their connection to a real estate purchase or sale may rely on professional intermediaries—such as real estate brokers, lawyers, and accountants—to engage directly with financial institutions. Such intermediaries may be directly complicit in the concealment and aware that the true identity of their customer would raise questions about the transaction. Or they may simply be following professional rules that mandate professional secrecy regarding their clients.
• Manipulation of property values. Although real estate pricing is somewhat predictable, prices are sufficiently subjective to justify inflated or deflated pricing in service of laundering schemes.
o Two co-conspirators may arrange a sale of a property for a sum that does not represent its market value, with the difference being paid in cash: for example, the sale price is 20% higher than the market value, and the seller repays the buyer in cash. A purchase price higher than market value may be justified to authorities on the grounds that the property was perfect for the buyer's needs, or the buyer was anxious to complete the sale quickly. Similarly, a purchase price below market value may be justified on the grounds that the seller wanted a quick sale, or the property had structural issues.
o Illicit actors may conspire with corrupt officials or bank employees to inflate the assessed value of a property, facilitating these schemes.
o A criminal may also disguise illicit transfers as loans raised using the property as security. The higher the value of the property, the more money that can be laundered using this technique.
• Sequential selling. The repeated selling of real estate by a group of conspirators, or by a single individual using multiple shell companies, in an attempt to separate the ultimate owner from the criminal proceeds originally used to purchase the property. In many cases, the same individual(s) will buy the property or sell the property multiple times.
3 Available at https://www.centralbank.ae/en/cbuae-amlcft.
2.2.4 Regulation and Supervision of the Real Estate Sector in the UAE
2.2.4.1 Regulation of the Real Estate Sector
Regulation of the real estate sector as a whole—as opposed to regulation of real estate professionals—is the responsibility of each of the emirates and as a result varies across the UAE. This section discusses key aspects of regulation of the sector in Dubai and Abu Dhabi, the two largest property markets. Section 2.2.4.2 discusses regulation of real estate agents and brokers.
2.2.4.1.1 Openness to Foreign Purchasers
• Dubai: With the exception of nationals of the Gulf Cooperation Council (GCC), non-residents and non-citizens of the UAE are permitted to own real estate in Dubai only in one of the designated real estate investment areas. In general, foreign purchasers must be individuals; legal persons are not able to purchase real estate in the investment areas unless they make the purchase through a subsidiary incorporated in a Free Zone. Foreign trusts and other legal arrangements, including trusts or legal arrangements established in the Free Zones, are also not permitted to purchase real estate anywhere in the Emirate.
• Abu Dhabi: As in Dubai, foreigners are permitted to purchase real estate in Abu Dhabi only in one of nine designated real estate investment areas. Within these areas, there are no restrictions on the type of property they can own or the period of time for which they can own it. Outside of these areas, foreigners cannot exercise freehold ownership of property, although they can exercise other forms of long-term ownership, such as leaseholds and usufruct rights.
2.2.4.1.2 Residency Rights
Owners of freehold properties above a certain value may obtain an investor visa that grants them limited residency rights in the UAE. The larger the value of the property, the longer the length of the visa. Visa rules are set by the UAE federal government through Cabinet Resolution (56) of 2018 on Regulating the Residence Permits for Investors, Entrepreneurs and Specialised Talents, and thus apply to all emirates:
• Ownership of a property worth at least AED 1 million comes with a six-month multi-entry visa. Dubai will grant a three-year renewable residency visa in such circumstances.
• An individual who purchases a property of at least AED 5 million and retains it for three years is entitled to a five year residency visa.
• An individual who purchases a property of at least AED 10 million without a mortgage or other loan and retains it for three years is entitled to a ten year residency visa.
2.2.4.1.3 Use of cash
There are no legal restrictions on use of cash to purchase real estate or property in Dubai or Abu Dhabi.
2.2.4.2 Regulation and Supervision of Real Estate Professionals
Real estate agents and brokers in the UAE are required to be licensed. The Land Departments or municipality of each emirate and CFZ are responsible for granting licenses in the Mainland and CFZs; the Financial Services Regulatory Authority (FSRA) and Dubai Financial Services Authority (DFSA) license real estate agents in the FFZs.
Under Article 3 of AML-CFT Decision, real estate agents and brokers qualify as DNFBPs when they “conclude operations for the benefit of their Customers with respect to the purchase and sale of real estate." When they qualify as DNFBPs, real estate agents and brokers must comply with the same AML/CFT preventive measures as LFIs, including the requirements to conduct a risk assessment, perform CDD, and report suspicious transactions.
The Ministry of Economy supervises real estate professionals in the mainland and CFZs for compliance with AML/CFT obligations, and the FSRA and DFSA supervises them in the FFZs. The Ministry of Economy has issued guidelines for supervised entities describing their AML/CFT compliance obligations.4
4 These guidelines may be found at https://www.economy.gov.ae/english/Pages/AML.aspx.