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UAE FINANCIAL
INTELLIGENCE UNIT (UAEFIU)
A N N U A L R E P O R T
UAEFIU@uaefiu.gov.ae | www.uaefiu.gov.ae
Table of Contents

Message from the Chairman of the National Anti-Money Laundering and Combatting Financing of 03
Terrorism and Financing of Illegal Organizations Committee

Message from the Head of UAEFIU 05

Vision, Mission and Values 06

Organisational chart and brief history 07

Overview of 2021 figures 08

UAEFIU sections 1. International Cooperation (ICS) 09

2. Operational Analysis (OAS) 10

3. Research and Strategic Analysis (RSAS) 12

4. Domestic cooperation (DCS) 15

5. Policy Outreach (POS) 16

6. Strategy (SS) 19

7. Systems Infrastructure (SIS) 20

Annexes

UAEFIU Legal Framework 22

Key statistics of 2021 I. International Cooperation Section (ICS) 23

II. Operational Analysis Section (OAS) 24

III. Domestic Cooperation Section (DCS) 27

Collaboration with stakeholders 29

Glossary 30

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 2

Message from the Chairman of the National
Anti-Money Laundering and Combatting
Financing of Terrorism and Financing of
Illegal Organizations Committee
From H.E. Khaled Mohamed Balama

2021 was another productive year for the UAEFIU. Executive Office (EO) to Combat Money Laundering
After our nation celebrated its fiftieth anniversary and Terrorist Financing in February 2021. The EO is the
in December 2021, looking forward to the next half- primary national body coordinating AML/CFT efforts
century of prosperity and progress, key national within the UAE, assisting related entities (including
institutions need to ensure the right conditions to allow UAEFIU) to enable a strong, sustainable national
the UAE’s economy to continue to flourish safely. AML/CFT structure. This demonstrates clearly the
UAE’s political commitment to implement an effective
Amidst ongoing challenges to our financial system system to deliver the requirements of the last FATF
at home and abroad, the UAE is keen to shoulder Mutual Evaluation Report in late 2020.
its international responsibilities as a leading global
financial centre, whose role is expanding further We enhanced the EO’s creation by confirming Ali Faisal
with the development of new fintech, green finance Ba’Alawi as Head of the UAEFIU in April 2021.
and other new lines of business. These investment Mr. Ba’Alawi had been acting head of the Unit since
opportunities bring associated challenges for the March 2018, and brings over a decade of specialist
UAEFIU to consider, assess and address within its experience to this role. This allows the UAEFIU to move
expanding role in the national financial governance forward with a strong leader to develop the required
framework. plans and processes from a firm base.

As part of the UAE’s National AML/CFT Strategy I shall leave it to Ali to expand on the UAEFIU’s specific
and National Action Plan, the UAE strengthened its achievements in 2021, but I would like to mention two
systems to combat financial crime by creating an specific FIU successes domestically. Its agreements

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 3

with the UAE Ministry of Community Development technology. I am sure that it will continue to enhance
to coordinate AML/CFT efforts in the not-for-profit its capabilities as an important part of the UAE’s
(charitable) sector, and with the Dubai Police General financial infrastructure, defending the nation from
Command to establish a Joint Operations Room to AML/CFT threats and working with its regional and
combat money laundering crimes), are good practical international partners as an integrated part of global
examples of the UAEFIU converting important financial markets. I thank everyone at UAEFIU for
international policy objectives into practical crime their hard work on this important task during 2021,
prevention measures. and ask for their renewed dedication to national and
international AML/CFT issues in 2022 and beyond.
In conclusion, the UAEFIU has a critical AML/CFT
role to perform for the nation, as the UAE offers an
increasingly attractive investment environment, H.E. Khaled Mohamed Balama
a secure home for funds and bank accounts, and a Chairman, NAMLCFTC
forward-looking trading nation at the forefront of

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 4

Message from the Head of UAEFIU
Ali Faisal Ba’Alawi

Looking back at 2021, it was an exceptional and a behavioural patterns, to detect new developments and
transformational year of the UAEFIU. It has been one to assess new money laundering and terrorist financing
of the most challenging, and also, productive years for risks. Six strategic analysis products/themes were
the Unit. In 2021, we witnessed the highest numbers completed in 2021 and shared with private and public
produced in relation to proactive disseminations, sectors.
intelligence sharing and engagement with our
international partners, complemented with the Notwithstanding these successes, the UAEFIU
signing of a number of Memoranda of Understanding will continue to invest further in its human and
with counterpart Financial Intelligence Units. technology resources. In collaboration with domestic
I am also pleased to have seen positive feedback and international partners, it will increase its efforts
on improvements in the quality and timeliness of to combat financial crimes to protect the integrity of
intelligence shared with our strategic partners. UAE’s financial ecosystem from being abused by
illicit actors.
As a result of the efforts by the relevant authorities
in tackling financial crimes, the number and quality of To conclude, I would like to recognise the effort and
Suspicious Transactions Report/Suspicious Activity dedication of UAEFIU’s staff and thank them for
Reports (especially from the Real Estate and Dealers their hard work and commitment in ensuring that the
in Precious Metals and Stones sectors) has increased, UAEFIU meets its mission and objectives. We look
demonstrating a better understanding of the money forward to similar success in 2022.
laundering and terrorist financing risks faced by the
different sectors.
Ali Faisal Ba’Alawi
As a strategic partner to the Law Enforcement and Head of UAEFIU
National Security agencies, we continued building
more efficient mechanisms to disseminate intelligence
to instigate investigations or support ongoing
enquiries. Compared to previous years, there has been
a significant increase in the number of intelligence
packages sent to Law Enforcement Authorities.

In 2021, the UAEFIU established a dedicated function

to conduct Strategic Analysis on data and information
available to the Unit to identify trends, typologies and

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 5

Vision, Mission and Values

Vision Mission
To be a leading Financial To produce actionable financial
Intelligence Unit in the intelligence for the fight
protection of global financial against money laundering, its
integrity, peace and security. predicate offences and terrorist
financing, at both the national
and international levels, through
the continuous enhancement
of subject matter expertise,
methods, and technology.

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

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 6

Organisational Structure

H.E.
the Governor

Financial
Intelligence
Unit

International Policy & Operational

Cooperation Outreach Analysis

Strategy Domestic Research and System

Cooperation Strategic Infrastructure
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).

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 7

Overview of 2021 Figures1

17,082 3,525
Domestic Cooperation
STRs received
requests received

2,985 14,225
Reporting Entities
SARs received
registered in goAML

7,185 923
Participants in the UAEFIU
Incoming RFI/SDs
awareness programs

145
Cases disseminated to 384
LEA (includes 1,212 STRs/ Outgoing RFIs/SDs
SARs/other reports)

1 The figures here are expanded in the Statistical Annex to this report.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 8

1. International Cooperation
Section (ICS)

The ease with which people and financial resources cooperation with foreign Financial Intelligence
can cross national borders makes international Units (FIUs), in line with its strategic objectives,
coordination and cooperation a critical element in demonstrating the effectiveness of the UAE’s anti
the global fight against money laundering, terrorist money laundering and counter-terrorist financing
finance and associated crimes (ML/TF). To strengthen (AML/CFT) system as a whole.
and support international efforts to tackle the crimes
• Signed eight MOUs with strategic jurisdictions
of money laundering and financing of terrorism
in 2021 to exchange ML/TF-related financial
(ML/TF), the UAEFIU expanded its collaboration
intelligence. It seeks to conclude more MoUs to
and coordination with counterpart FIUs and other
enhance international cooperation, and will consider
international stakeholders throughout 2021.
partner organisations regardless of their Egmont
member status, often using MOUs as a foundation
The UAEFIU is tasked with gathering and exchanging
for international cooperation with non-Egmont
information on suspicious transaction reports (STRs)
member countries.
or any other information which the FIU has the power
to obtain or access, directly or indirectly, according to • Conducted 61 meetings with international
the international agreements to which the UAE is a stakeholders (including Egmont Group) to enhance the
party or any MOU(s) that the FIU has entered into with Bilateral Dialogue for Cooperation with partner FIUs.
counterparts to regulate their cooperation, or on the These promoted the timely sharing of high-quality
condition of reciprocity. financial intelligence and information of common
interest, identified trends and typologies and discussed
The UAEFIU has been an active member of the Egmont joint strategies to mitigate risks of mutual concern.
Group2 since joining on 5 June 2002. It follows up
• Received 727 requests for information and 196
on developments relating to ML/TF crimes through
spontaneous disclosures, and sent 285 requests
relevant regional and international organisations and
for information and 100 spontaneous disclosures
bodies, and participates in related meetings.
through its ICS team.

2021 Highlights • Reviewed its performance, by sending surveys

to the top 25 counterpart FIUs to measure the
The UAEFIU: effectiveness of their information exchanges. The
results revealed significant, actionable findings on
• Enhanced its international standing and
information-related results, quality and timelines.

2 Egmont Group is a group recognized as global organization which facilitates and prompts the exchange of information, knowledge, and cooperation
amongst member FIUs. (Website: https://egmontgroup.org/ )

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2. Operational Analysis Section (OAS)

The OAS mandate is to receive Suspicious Transaction OAS also initiates requests and the spontaneous
Reports (STRs) and Suspicious Activity Reports (SARs) sharing of information with international counterpart
from reporting entities, and to analyse this and related FIUs, based on the analysis of STRs/SARs and other
information from other sources, disseminating financial information. It conducts data analysis to detect
intelligence to law enforcement partners when entities that were not reporting, or whose reporting
warranted. behaviour varied significantly, including failure to
upload remittance reporting details.
To identify potential ML/TF cases, OAS follows a risk-
based approach to prioritise and analyse STRs/SARs
received, taking into account risk attributes identified 2021 Highlights
through the UAE’s national risk assessment, and various
sectorial risk assessments.
OAS underwent major changes in its structure and how
During case analysis, the OAS enhances the it undertakes its core functions in 2021. The UAEFIU’s
information in filed STRs and SARs with a multitude of Intelligence section was renamed as OAS, with a
other sources, including national level databases, other mandate to focus purely on operational-level analysis.
financial information and open source material. This This has allowed OAS to enhance the way it conducts
helps to identify specific or additional targets, to follow business, and has led to the following major changes:
the trail of particular activities or transactions, to trace
the flow of funds from sources to their destinations, • Quality of Intelligence: A radical overhauling of
and to determine links between those targets and its analysis and dissemination has provided more
possible proceeds of crime, ML and TF. valuable intelligence packages to LEAs for faster
and more effective decision-making. This includes
In addition to the information that entities report designing analysis reports to include technical
to the UAEFIU, OAS can request and use additional statements of fact, and narratives that add value
information from reporting entities and other beyond STR/SAR details. This is created by using
stakeholders. OAS also has access to a range of initial suspicions raised by a reporting entity, and
systems, databases, plus financial, administrative using all available sources and databases to create
and law enforcement data required to fulfil its hypotheses of what the analysis tells the OAS may
functions. This access enhances OAS’s ability to be happening. This can provide specific leads to LEAs
produce comprehensive intelligence reports on named as a focus for future investigation.
individuals and entities as subjects of any investigation.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 10

• New Report Types: The UAEFIU worked closely in 2021. These included sessions on Virtual Assets
with its stakeholders, including the UAE supervisory by the EU Facility, Egmont Group ECOFEL courses
authorities, to highlight possible areas of focus and HMRC training on Operational and Strategic
and improvement in each industry on reporting Analysis. OAS staff also pursued professional
suspicious activities and transactions. In 2021, certifications on financial crime topics.
the UAEFIU introduced five new report types in
• Human Resources: OAS’s human resources
goAML, improving and simplifying the reporting
increased by over 30% in 2021, compared to 2020.
mechanisms and requirements for financial
This enhanced the section’s capability to conduct its
institutions (FIs) and designated non-financial
core functions and fulfil its mandate.
business professionals (DNFBPs – this might include
estate agents, lawyers and other businesses whose
primary business is not financial). • Databases and Information: OAS enhanced its
information use by increasing the databases to
which it has access, and using the available data
• Methodologies: Reinvigorating the processes
in a more value- added manner. As an example,
used to address the highest risks of financial crimes
operational analysis now includes customs data
identified in the national risk assessment (NRA),
when conducting database checks, which is also
such as; fraud, Trade Based Money Laundering
used to link possible counterparties.
(TBML), and others, by enhancing goAML with
specific ‘Reason for Reporting’ (RFR) for use by
reporting entities, and by realigning the overall risk Operational Analysis and Dissemination to LEAs
based approach implemented internally to focus on
Generally, 2021 was a year of tremendous growth for
the riskier elements when conducting operational
OAS, both in terms of the quantity and quality of its
analysis.
products. It focused on higher risk areas when analysing
STRs and SARs, including TBML, fraud, professional
• Collaboration with Stakeholders: Two new report and third-party ML/TF. Compared to 2020, the number
types - Funds Freeze Report (FFR) and Partial Name of UAEFIU disseminations to the LEAs increased
Match Report (PNMR) – were introduced to report significantly by approximately 150% year-on-year.
financial activities of entities listed in targeted
financial sanctions lists. In addition, OAS acts as An important area of focus for OAS involved the
an intermediary between the Executive Office of UAEFIU’s mandate to exhaust all avenues of analysis
the Committee for Goods Subjected to Import before disseminating reports to LEAs, including by
and Export Control (EO IEC) and reporting entities engaging with counterpart FIUs at an early stage
utilising the goAML Message Board as a secure on cases being investigated. In 2021, the number of
communication channel. This allows reporting outward requests for information (ORFI) reached 284,
entities to fulfil their legal obligations by utilising an increase of 480% over the 2020 figure. These
a robust and familiar reporting system. ORFIs were important in helping the OAS to create a
detailed view of the case subjects under investigation,
allowing the UAEFIU to enhance its disseminated
• Communications: OAS enhanced its
Intelligence products.
communication with reporting entities by
developing a specific e-mail address for operational
OAS also used its analysis capability to identify data
queries related to STR and SAR filing. It also
with possible value to other jurisdictions in the global
established dedicated goAML Message Board
fight against financial crime. This can involve sending
templates for Reporting Entities’ use to ensure
spontaneous disseminations (SDs) to counterpart FIUs
faster and more organised correspondence.
that include information possibly beneficial to them.
The number of SDs issued in 2021 increased by 1,300%
• Staff Training and Development: OAS staff took over the 2020 figure, highlighting the UAEFIU’s serious
part in a range of capacity-building exercises, commitment to its role in the global AML/CFT battle.
bespoke and off-the-shelf training programmes

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3. Research and Strategic Analysis
Section (RSAS)

RSAS was officially added to the UAEFIU’s

Organizational Structure in early 2021, pursuant to 2021 Highlights
Section 4 of Article 41 of Cabinet Decision No. 2019,
which states that
RSAS issued six strategic analysis reports in 2021:
“FIU shall prepare studies, research and statistics
related to crime, and following up on any studies, • The abuse of Legal Entities in ML/TF
research or statistics conducted domestically or • The Abuse of Non-Profit Organisations
internationally in this regard.”
• Strategic Analysis on Trade-Based Money
RSAS has a mandate to: Laundering (TBML)

• define priority projects for strategic analysis; • Strategic Analysis on Money or Value Transfer
Services (MVTS) and Registered Hawala Providers
• determine gaps in current understanding of the (RHP)
topics;
• Strategic Analysis on Professional Money
• identify ML/TF-related trends and typologies; Laundering (PML) and Foreign Proceeds of Crime
• develop studies, reports, guidance and red flag • Strategic Analysis on Virtual Assets
indicators; and

• propose policy changes to deepen understanding The reports aimed to identify typologies and emerging
of the principal ML/FT risk drivers in the UAE. techniques, determine vulnerabilities, list red flag
indicators, and illustrate case studies related to the abuse
To deliver its strategic analysis products, RSAS collects, of the aforementioned sectors, and known ML schemes.
collates and evaluates all available information,
including data provided by other UAEFIU sections, International Coordination: RSAS made efforts to
other domestic authorities, foreign FIUs, reporting initiate coordination with relevant counterpart FIUs
entities and other pertinent sources. RSAS final reports deemed substantial in the findings of strategic analysis
are communicated to relevant stakeholders through reports. One example involved sharing of information
outreach and/or the sharing of reports and guidelines. with a counterpart FIU after discovering strategic
links to an identified criminal typology. Subsequent
face-to-face meetings followed to discuss the main
characteristics and investigation outcomes.

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Outreach Efforts: RSAS conducted three outreach sessions on the outcomes of strategic analysis reports:

Audience Audience Number of Attendees

• Domestic Banks
Session 1 Discuss and share 300
• Banks in DFSA and FSRA
the outcome of
• Foreign Banks/Rep. Offices strategic analysis:

• Money Exchange Houses • The Abuse of

Legal Entities
• Money Service Providers (supervised by
Session 2 165
FSRA) • The Abuse of
NPOs
• Finance Companies
• Strategic
AnalysisonTBML
Session 3 • Competent Authorities 40

Sharing of RSAS Reports: RSAS shared its strategic analysis reports with the NRA Sub-Committee, competent
authorities and the private sector (i.e. Reporting Entities).

Staff Training and Development: The RSAS staff received intensive strategic analysis training organized
by HMRC (UK) and other external parties. This included analytical and critical investigation techniques, assumption and
hypothesis formulation, the identification of links and patterns and other significant strategic analysis-related skills.

Trends, Typologies and Emerging Risks

The UAEFIU conducts qualitative and quantitative analysis on the data held on its databases to identify red
flag issues, trends and typologies of crimes. As part of its strategic analysis in 2021, RSAS identified several
patterns of crime. Illustrated below is a brief insight to the noted emerging techniques of criminality.

Pass-Through Accounts: The UAE’s strategic location Accordingly, the number of legal entities registered in
presents a potentially attractive jurisdiction through the UAE surged between 2020-2021, accompanied by
which money-launderers may try to funnel their funds higher risk of TBML. This might allow a (shell) company
to obscure its source and ultimate destination. Despite offering consultancy services to bill customers against
of the country’s stringent financial controls and AML/ “work” provided at unreasonably high prices. Similarly,
CTF measures, criminals attempt continuously to find front companies could be exploited to combine
loopholes to exploit for illicit purposes. legitimate and illegitimate trade, making illicit funds
appear clean once incorporated with licit funds.
Legal entities can also be abused as conduits or
intermediaries in the routing of funds between Proceeds of Fraudulent Activities through MVTS
jurisdictions. It was observed that free zone entities are Providers: With the continuous advancement of
often the subject of enquiries from counterpart FIUs, technology, especially in the telecommunication
due to their involvement in identified (or suspected) ML industry, communication services such as SMS, voice
layering activities. For example, one free zone entity calls, emails or social media platforms can be used by
in the UAE received significant funds from an offshore criminals to gain a financial advantage. The Covid-19
company in a high-risk jurisdiction. The transmitting pandemic and movement restrictions in recent years
parties were not in the same line of business, nor have persuaded many people to stay at home, providing a
presented supporting evidence to sustain the great opportunity for fraudsters to exploit the innocent.
transaction’s purpose, thus raising ML/TF suspicions to
UAEFIU investigators. During 2021, the UAEFIU received over 200 STRs
concerning repeated fraud types, such as, ‘advance
Shell Entities: The UAE introduced minimum fee scams’, ‘phishing and vishing’, ‘E-mail compromise
requirements to open a business as one of many fraud’, ‘inheritance fraud’ and ‘internet or mobile
initiatives to encourage trade and boost its economy, banking fraud’. It was noted that MVTS providers
enhancing its already attractive location. (notably exchange houses) were being exploited by
criminals to route fraudulent proceeds.

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Underground Hawala through Legal Entities: house. Whilst in the second scenario, the cash couriers
Usually, Hawala providers provide their exchange straightforwardly declare that the funds are intended
and financial transmission services as their primary for an Exchange House.
business, or as an ancillary service with other
business activities. Some general trading companies Routing Fraudulent Foreign Proceeds of Crimes
licensed under the UAE Ministry of Economy are also (Cyber-crimes):
“Registered Hawala Providers” (a CBUAE registration Large-scale financial crimes, such as cyber-crimes,
function). involve different networks and jurisdictions globally to
avoid the detection and tracing of stolen funds.
Based on strategic analysis, a number of Legal Cyber-criminals recruit ‘money mules’ to move
Entities (LEs) were observed engaging in unlicensed illegally-derived proceeds via electronic transfers or
or unregistered hawala activities, without a CBUAE physical cash movements to mask the true source of
“Hawala Provider Certificate” in addition to their normal funds.
commercial activities. Unregistered hawala providers
tend to mix funds specific to hawala activities with 14% of the intelligence reports received from
other income from regular business. Other “Shell” counterpart FIUs were Fraud related inquiries or
entities are established primarily to conduct unlicensed spontaneous disseminations.
or illegal hawala activities.
As of the UAEFIU’s database pertaining to the
One commonly-used technique of settlement is the intelligence reports received from counterpart FIUs,
“reverse hawala” between two or more hawala providers found mainly related to ‘fraud’. Such reports constitute
within the same network. The hawala companies inquiries/information mainly on; Possible Fraud (46%),
exploit trade transactions (TBML techniques), with Possible Investment Fraud (13%), Possible Forgery
settlements conducted through wire transfers or using (10%), Possible Fraudulent Wire Transfer (10%) and
cash couriers or cross-border cash movements for Possible Business Email Compromise Fraud (10%).
settlement.
Legal Entities/Shell Companies controlled by
Recruiting Money Mules ‘Cash couriers’ for Cross- Professional Money Launderers (PML):
Border Cash Movements: Criminals – usually organized crime groups - entrust
A common trend noted involving individuals arriving to PMLs to set up mechanisms and infrastructures
the UAE carrying large cash from various jurisdictions to make their ill-gotten funds “untraceable”. PMLs
(predominantly high-risk). Cash transported is in transfer funds to various LE accounts (often front or
different currencies and declared to the local customs shell companies controlled by them), which are then
authority in favour of a Legal Entity or an Exchange transferred through another layer of LEs or shell
House. In the first scenario, the LEs that couriers companies. This ML scheme can occur in the same
declared cash for is not the actual beneficiary of the jurisdiction as the original crime, or another jurisdiction,
funds. The LEs is only being used as a front/shell as part of cross-border ML scheme.
company to receive funds on behalf of the exchange

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 14

4. Domestic Cooperation Section
(DCS)

DCS coordinates the exchange of information with enable policy makers, the Financial Intelligence Unit
domestic competent authorities such as PP, LEAs, (FIU), law enforcement authorities, supervisors, and
and supervisory authorities, and collaborates with other relevant competent authorities to co-operate,
them to fulfil its functions effectively, contributing and where appropriate, co-ordinate, and exchange
to overall efforts against money laundering, information domestically with each other concerning
associated predicate offences, and terrorist the development and implementation of AML/CFT
financing. In addition, DCS receives requests to policies and activities. Such mechanisms should apply
conduct searches on named subjects (natural or at both policymaking and operational levels.”
juridical), account details held with LFIs, orders to
‘Freeze’ or ‘Unfreeze’ account(s) balances, and other
requests for mutual legal assistance. 2021 Highlights

Upon signing MOUs between the FIU and Competent

DCS:
Authorities (as supervisory authorities, LEAs, and
other strategic partners), DCS participates in joint • Signed Three Memoranda of Understanding (MOUs)
committees to enhance coordination, information- with domestic stakeholders;
sharing and the exchange of expertise. • Conducted one workshop and seven meetings with
Law Enforcement Authorities, State Security and
This section also provides operational assistance to Public Prosecutions, to discuss current issues and
LEAs and PPs, including preparing comprehensive challenges, and to strengthen cooperation between
analytical reports for investigations, identifying domestic stakeholders; and
potential cases of ML or TF, and - in some cases -
providing recommendations and guidance. • Issued 321 technical reports (comprehensive reports
including in-depth analysis of account statements
DCS meets FATF Recommendation 2 (Domestic and transactions) prepared upon request for
Cooperation and Coordination) for member states, relevant stakeholders.
which notes that “mechanisms should be in place to

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 15

5. Policy and Outreach Section
(POS)

POS continued to fulfil its mandate to conduct

outreach sessions to increase the AML/CFT 2021 Highlights
awareness of FIs and DNFBPs, and with other AML/
CFT supervisory or law enforcement authorities. It
POS:
developed, reviewed and updated relevant policies and
procedures in line with national laws and regulations, • Developed a new outreach plan for all stakeholders
and international standards. and reporting entities, based on:

− Sectoral risk assessments

Its Policy function reflects its expert status on legal
and policy matters for the UAEFIU, coordinating with − Recent national risk assessments (NRA)
internal clients to provide recommendations and advice − Operational analysis outcomes
on any issues, including support in issuing Notices,
Circulars, Guidance and best practice, and providing − Strategic analysis plans and projects
interpretation when requested. − Any AML/CFT-related topic of interest to
Regulators or Regulated Entities
The Outreach section provides training, outreach
• Developed new domestic and international
and awareness sessions for all reporting entities
cooperation frameworks
on a regular and frequent basis, or when deemed
necessary. The section creates training/outreach and • Conducted 21 outreach sessions and workshops
communications plans to raise awareness on AML/CFT covering AML/CTF topics
risks and relevant international standards.
• Engaged with high-risk sectors and supervisory
authorities continuously to improve the quantity
Additionally, the section oversees:
and quality of STRs/SARs

• Sufficient, relevant training for all FIU members on • Coordinated 33 training sessions for FIU members
quarterly basis
• Collaborated with competent authorities and
• FATF-related matters (POPR, trainings, planning) stakeholders to identify operational gaps and
propose solutions
• Sub-committee(s) meetings

• The revision of laws, rules, and guidance

• Drafting and issuing notices.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 16

Publications

The POS Policy function participated in reviewing and amending 18 documents during 2021 in coordination with
CBUAE and other supervisory authorities and stakeholders. These documents included guidelines, notices, typologies,
laws and regulations.

Type Subject

Guidance Guidance for licensed financial institutions on suspicious transaction reporting

GuidanceforLicensedFinancialInstitutionsontherisksrelatingtoDealersinPreciousMetalsandStones
Guidance
and the Real Estate Sectors

Guidance for registered hawala providers and for licensed financial institutions providing services to
Guidance
registered hawala providers

Guidance Targeted Financial Sanctions (TFS) guidance

Guidance Guidance CBUAE Transaction Monitoring and Sanctions Screening

Guidance DPMS Simplified Reporting guidelines

Guidance AML/CTF guidelines

Guidance FATF High Risk Countries and Jurisdictions under increased monitoring

Guidance Guidance on Partial Name Match & Funds Freeze Reports

Guidance CBUAE AML/CFT Guidance for Insurance Sector

Guidance Allocation of Tasks and Responsibilities of public authorities on TFS

Guidance CBUAE guidance for licensed financial institutions providing services to cash-intensive businesses

Guidance for Investigative Authorities on ML investigations and prosecutions including seizures &
Guidance
confiscation

FIU Notice Dealers in Precious Metal and Stones – Frequently Asked Questions (DPMSR FAQs)

FIU Notice FATF High Risk Countries and Jurisdictions under increased monitoring revision and FAQ

Typology Paper on the circumvention of Targeted Sanctions against Terrorism and the Proliferation of
Typology
Weapons of Mass Destruction

ML/TF typologies in the financial sector (Supervisory Authorities Sub-Committee and the Financial
Typology
Intelligence Unit)

Amendment Decree 26 of 2021 to the Decretal Federal Law No. (20) of 2018 on Anti Money
Law
Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 17

Training and Awareness Number of outreach session
Training and outreach sessions included regular
presentations, workshops and seminars for RE
across various sectors (notably sectors or businesses
vulnerable to ML/TF) to create or raise awareness
on ML/TF risks and emerging trends, and how to
mitigate those risks. 47% 53%

The UAEFIU also conducted 21 awareness

programmes in 2021, focusing on high-risk sector,
which 7,185 participants attended from FIs, DNFBPs
and competent authorities. The courses covered
risk factors for DNFBPs, reporting requirements
and identification of suspicious transactions, FIS DNFBPs
ML investigations, Red Flag Indicators and case
studies on ML/TF, trends & typologies and goAML In addition to the training mentioned above, all UAEFIU
registration. employees completed the ECOFEL/E-learning training
relevant to their sections. The 2021 training figures also
show a healthy increase over 2020, rising to 32 from 25.
Total
Sector Service provider
Number

Bank Training sessions attended by UAEFIU Employees

Exchange house
FIS 10 40
Insurance Companies & brokers

Hawaladar 30
DPMS

Lawyer 20

DNFBPs Real Estate 11

10
CSP

Accountant and Auditors 0

2020 2021

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 18

6. Strategy

The Strategy Section seeks to deliver the UAEFIU’s

overall strategic goals through a yearly operational 2021 Highlights
plan, developed in alignment with UAEFIU’s
mission and vision statements (see page 5) and in
coordination with other Sections. UAE POPR (Post Observation Period Report):
The section led the preparation of the FIU element
This: in the UAE POPR for the FATF Joint Working Group
• Ensures adherence to the approved UAEFIU follow-up meetings and subsequent questions.
business model, national priorities (National
Strategy, National Action Plan, others) and Coordinated with internal and external stakeholders
international best practice. on UAEFIU matters, including the Executive Office of
AML/CFT and the consultants.
• Monitors and measures implementation of the
UAEFIU’s operational plan and the National Action
Plan, in coordination with relevant Sections and
authorities through predefined qualitative and
quantitative KPIs. It also prepares quarterly and
yearly performance reports.

• Plays a key role in liaising with domestic

authorities and other FIU sections to support
implementation of the National Strategy and
improving the UAEFIU’s efficiency.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 19

7. Systems Infrastructure Section (SIS)

SIS’s main objective is to help the UAEFIU to become Targeted Financial Sanctions and Proliferation
one of the top FIUs worldwide for its advanced Financing - namely, FFR and PNMR. Financial
technology, utilising innovation, optimisation and Institutions (FIs), DNFBPs and Virtual Assets
standardisation. Services Providers (VASPs) are required to
file these reports upon identification of a
SIS responsibilities include: sanctioned person or entity.
• Managing and administering UAEFIU-owned
− Other reports include High Risk Countries reports
information systems and databases, including its
based on the National Anti-Money Laundering
applications, intranet and website support, databases,
and Combatting Financing of Terrorism and
system setup, software configurations and other tools.
Financing of Illegal Organizations Committee
• Developing and implementing business continuity (NAMLCFTC) directives4.
plans, user review exercises for all internal and
• Publication of new, enhanced System Guides for
external users of UAEFIU information systems,
reporting entities, answering questions on systems-
disaster recovery and back-up for all FIU systems,
related matters (available on UAEFIU Website5).
and redundancy and contingency plans to protect
the systems, databases and equipment. • Introduction of IEMS system enhancements to
ensure smooth functionality and effectiveness.
• Designing, developing and implementing scenarios
A new platform, FIU Enquiry, was developed
and thresholds for the UAEFIU’s Risk-based
to benefit the FIU’s major partners within the
Approach (RBA) methodology and its automation.
country to share intelligence securely.
• Providing technical support to all FIU staff and
• Ongoing digital transformation for UAEFIU’s
external stakeholders.
operations to optimize its functions for AML/
CFT purposes and to overcome the practical and
operational challenges arising throughout different
2021 Highlights
stages and processes in the daily operations.

• The number of entities registered on the goAML

• Launch of the new UAEFIU Website in August 20213
platform rose sharply in 2021 (by 784%), due
• Introduction of new goAML reports to enhance to the joint efforts of the UAEFIU and other
the level of intelligence disseminated to Law competent authorities to cover various sectors of
Enforcement Authorities in the UAE: UAE’s economy vital to combatting ML/TF.
− Two new reports were introduced to support the • Increasing SIS resources by 50% between
functions of EO IEC 2020-21, reflecting UAEFIU’s commitment to its
(https://www.uaeiec.gov.ae/en-us/) in relation to operational capacity enhancement strategy.

3 https://www.uaefiu.gov.ae/en/
4 https://www.namlcftc.gov.ae/en/more/jurisdictions/high-risk-countries/
5 https://www.uaefiu.gov.ae/en/more/knowledge-centre/system-guides/

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 20

Future Outlook
Inspired by Innovation and Technology

The UAEFIU is adopting a digital transformation initiative to

optimise its AML/CFT functions to overcome practical and
operational challenges arising in its daily operations, in line with
the latest FATF Guidance.

The initiative’s main objective is to use the FIU’s resources to

produce higher-quality intelligence products to serve the UAE’s
main goal to identify, disrupt and punish ML/TF criminals and illicit
financial networks. It aims to create new report types to facilitate
intelligence gathering and enriching the data available for analysis.

The UAEFIU is also upgrading goAML to the latest UNODC version

to benefit from the latest technology available for FIUs to receive,
analyse and disseminate financial crime intelligence.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 21

ANNEXES
Legal Framework

Although the UAE criminalised the acquisition of (or the UAE scored highly in the Technical Compliance
concealing) criminally-obtained proceeds, or proceeds section of the latest FATF Mutual Evaluation Report
obtained in circumstances which lead to suspicion (April 2020). It achieved a “Compliant or Largely
that their source is illegal in its Penal Law of 19876, Compliant” rating in 34 out of 40 recommendations.
it only issued special penal legislation to criminalise To enhance further the level of compliance to FATF
money laundering specifically for the first time in 2002 recommendation and to tackle its new requirements,
(Federal Law No. (4) of 2002). This law was amended including those related to VASP, the UAE amended
in 2014. some provisions of the AML Law and added new
provisions by issuing Decretal Federal Law No. (26) of
The UAE has evolved since to fight ML/TF effectively 2021. As a result, the UAE achieved a “Compliant or
by adopting a mature and vigorous AML/CFT legal Largely Compliant” rating for Technical Compliance in
framework: 36 out of 40 FATF recommendations10.
• Decretal Federal Law No. (20) of 2018 (AML Law)7 and
its amendments - repealed Federal Law No. (4) of 2002. The UAE legal system includes legislation which serves
as the AML/CFT framework in the UAE. For example,
• An Executive Regulation (AML By-law) to the AML
the UAE Cabinet adopted Decision No. (20) of 2019
Law of 20198 by Cabinet Decision No. (10) of 2019
concerning the Implementation of UNSCRs Relating
streamlined the system by applying a unified AML/CFT
to Countering and Preventing Terrorism and Terrorism
legal framework across all Emirates, Commercial Free
Finance and Countering the Proliferation of Weapons
Zones (CFZs) and Financial Free Zones (FFZs) in the UAE.
of Mass Destruction and All Related Resolutions (“the
UNSCR Decision”) as the legal framework to implement
The AML Law and By-law cover all requirements of the TFS.
2012 FATF recommendations and its methodology of
20139 , in harmony with the UAE legislative system. The TFS legal framework was further enhanced in
This is a fundamental legal pillar, and contributes to 2020 by Cabinet Decision No. (74) of 2020 concerning
raising the effectiveness of the legal and institutional the Terrorism Lists Regulation and Implementation of
framework of the nation to achieve the desired results. UN Security Council Resolutions on the Suppression
As a result of its vigorous AML/CFT legal framework, and Combating of Terrorism, Terrorist Financing,

6 which has been revoked by Decretal Federal Law No. (31) of 2021 “Federal Crime and Punishment Law”
7 https://www.mof.gov.ae/en/lawsAndPolitics/govLaws/pages/moneylaundering.aspx
8 https://www.mof.gov.ae/en/lawsandpolitics/cabinetresolutions/pages/201910.aspx
9 For more on the FATF recommendation, visit http://www.fatf-gafi.org/publications/fatfrecommendations/?hf=10&b=0&s=desc(fatf_releasedate)
10 ReferstothefirstFollow-UpReportoftheUAEhttps://www.fatf-gafi.org/media/fatf/documents/reports/fur/MENAFATF-FUR-UAE-Nov%202021.pdf

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 22

Countering the Proliferation of Weapons of IRIs & ISDs received from Counterpart FIUs
Mass Destruction and its Financing and Relevant 01/01/2019 to 31/12/2021
Resolutions11. This revoked Cabinet Decision No. (20)
of 2019 in favour of an enhanced level of national 800 727
technical compliance to recommendations 6 and 7, 611
600 586
resulting in the status change from Partially Compliant
to Compliant.12
400

The UAE Cabinet also issued Decision No. (58) of 2020 179 196
200 158
concerning the Beneficial Ownership Information,
which develops the business environment, capabilities 0
and economic status of the UAE to international Incoming Requests Incoming Spontaneous
requirements by regulating the minimum commitments for Information Disseminations
of registered and legal persons in the UAE. This
2019 2020 2021
complements effective, sustainable executive and
regulatory mechanisms and procedures relating
to the data of beneficial owners. The Decision
identifies beneficial owners and outlines the licensing I.A.2. Top 10 Countries UAEFIU received Requests for
or registration of legal persons (transparency Information (IRIs) from in 2021
requirements, beneficial owner notifications, registering
Country % Volume of IRIs
the beneficial owner and the partners or shareholders
registry). It also clarifies the means for providing and Saudi Arabia 12%
amending data, domestic and global cooperation, data
India 8%
confidentiality, administrative penalties, grievances
and nullifications.13 United States 7%

Pakistan 6%
2021: Key Statistics Kazakhstan 4%

United Kingdom 4%
This chapter outlines the UAEFIU’s most significant Malta 3%
statistics in an expansion of data presented in the
Overview of 2021 Figures (page 7). For the purpose of Netherlands 3%
comparability, the majority of the information below Moldova 3%
covers three-year period 2019-21.
Montenegro 2%
I. International Cooperation Section All Other Countries14 48%
In respect of cooperation with counterpart FIUs,
ICS utilizes four main reports namely: Top 10 Countries (IRIs 2021)
• Incoming Request for Information (IRI); 12

• Outgoing Request for Information (ORI); 8

• Incoming Spontaneous Dissemination (ISD); and 48% 7

• Outgoing Spontaneous Dissemination. 6

4
In the past three years, there is an overall increasing 4
trend noticed in terms of quantity of reports 2 3 3 3
particularly the ORIs and OSDs. Comparing the data
between 2019 and 2021, IRIs increased by 19%, ISDs by Saudi Arabia India
10%, ORIs by 668% and OSDs by 163%. United States Pakistan
Kazakhstan United Kingdom
I.A.1. Total Number of Incoming Requests Malta Netherlands
for Information and Incoming Spontaneous
Moldova Montenegro
Disseminations from Counterpart FIUs from 2019
to 2021 All Other Countries 14

11 Laws and Regulations Details | Committee for goods & material subjected to import & export (uaeiec.gov.ae)
12 Refer to the first Follow-Up Report of the UAE https://www.fatf-gafi.org/media/fatf/documents/reports/fur/MENAFATF-FUR-UAE-Nov%202021.pdf
13 1b153968-3ad0-e271-eda7-aa23562326ac (moec.gov.ae)
14 All other FIUs consist of 100 other counterpart FIUs.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 23

The UAEFIU, through the ICS, has received 727 IRIs Top 10 Countries (ORIs 2021)
from counterpart FIUs (Egmont or non-Egmont
9
members) in 2021. Among these requests, 6% were 6
5
related to possible illegal hawala, 6% is linked to possible
4
TBML, 6% is associated to possible tax crimes, etc. 4
58% 3
I.B.1. Total Number of Outgoing Requests 3
for Information and Outgoing Spontaneous 3
3
Disseminations from Counterpart FIUs 2
from 2019 to 2021

United States Saudi Arabia

ORIs & OSDs sent to Counterpart FIUs
United Kingdom Hong Kong
01/01/2019 to 31/12/2021
India Pakistan
300 284 Singapore Switzerland
Turkey Germany
200 All other Countries 15

100 The UAEFIU has sent a total of 284 ORIs to

100
49 38
counterpart FIUs. ORIs are mainly initiated by OAS
37
7 when it is assumed that a particular jurisdiction is
0 integral to the analysis of a case, and their data
Outgoing Requests Outgoing Spontaneous
for Information Disseminations
may add value to the intelligence for dissemination
to the LEA. These requests are mainly related to
2019 2020 2021 predicate offences of possible Boiler Room fraud
(13%), Possible Fraudulent Wire Transfers (10%),
Possible Unexplained Income or Assets (7%), Possible
Corruption or Bribery – PEP (7%), Possible Illegal
I.B.2. Top 10 Countries UAEFIU sent Requests for
Mining – Gold (7%), etc.
Information (ORIs) to in 2021

Country % Volume of ORIs II. Operational Analysis Section

United States 9% II.A. No. of Cases (incl. Reports) Disseminated to the

Saudi Arabia 6% Law Enforcement Authorities (2020-2021)

United Kingdom 5%
No. of Disseminations to LEA
Hong Kong 4%

India 4% 160 145

Pakistan 3%
120
Singapore 3%
80
Switzerland 3% 58
Turkey 3% 40
Germany 2%
0
All Other Countries15 58% Number of Cases

2020 2021

No. of Reports Included in the Disseminations

STRs/SARs Other Report Types Total

510 702 1212

15 All other FIUs consist of 79 other counterpart FIUs

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 24

The volume of cases disseminated to the LEA in 2021 rose by approximately 150%, compared to the 2020 figure.
A similar increase occurred in the types of cases investigated by the OAS, across a wide range of typologies.

These included:

Percentage of Total
No. Typology
Disseminations

1 Fraudulent Transfer (Domestic & International Fraud Recall) 26%

Possible laundering in UAE of proceeds from foreign predicate offences (including

2 16%
direct and indirect tax crimes)

3 Possible Professional Third-party ML or Networks of Third-party Laundering 12%

4 Possible Trade-Based Money Laundering 12%

5 Possible money laundering involving high-risk sectors such as MVTS or DPMS 11%

Cases involving complex money laundering methodologies and/or businesses/

6 8%
companies in higher risk sectors, including cash and PMS smuggling

7 Possible Terrorist Financing 8%

8 Others 6%

II.B. OAS’s International Elements II.C. Total Number of Reports by Sector

In 2021, the UAEFIU has received 21,707 reports,

No. of International Outward Requests initiated by excluding DPMSRs 16 , of which FIs submitted
OAS to Counterpart FIUs 96% (20,919 reports). DNFBPs filed 366 reports,
in addition to 194 reports from Virtual Assets
300 284
Service Providers (VASPs) and 228 reports from
both supervisory and competent authorities.
200 After introducing the new DPMSR report type
in June 2021, which is specifically utilised by the
100 DPMS sector, the UAEFIU has received 158,768
100
DPMSRs by the end of 2021.
49

7
0
Number of Number of
ORFIs sent SDs sent

2020 2021

16 Includes STRs, SARs, HRCs, HRAs, FFRs and PNMRs.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 25

The information below illustrates the change in volume of reports filed by each sector to the UAEFIU during 2021 in
comparison to 2020.

DNFBPs 2020 vs. 2021 Others (supervisory authorities and competent

authorities) 2020 vs. 2021
400 366
240 229 228
300
160
200

100 80
26
0
0
No. of Reports
No. of Reports

2020 2021 2020 2021

VASPs 2020 vs. 2021 Financial Institutions 2020 vs. 2021

25,000
300 20,919
20,000
194 16,267
200
15,000

100 10,000

0 5,000
0
No. of Reports 0
No. of Reports

2020 2021 2020 2021

Overall, there was a 31% increase in the total reports received in 2021. The change is mainly due to two factors:
additional reports submitted falling under the category of the four new report types introduced in the same year
and increased number of the UAEFIU’s targeted outreach sessions and training.

DNFBPs sector reports (from lawyers and notaries, trusts and CSPs, accounts and auditors, DPMS, and real estate
agents and brokers) surged significantly by over 1300% - a welcome addition of data from the non-financial
sector.

There is no comparative data for the VASPs sector, as it only registered on goAML late in the third quarter of
2021. Nevertheless, this sector made 194 reports by the end of 2021. Consequently, the volume of reports filed by
supervisory authorities and competent authorities declined slightly by 0.44%.

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 26

II.D. Report Types

In 2021, the UAEFIU added an array of new report types to the goAML platform. These help to monitor some of the
high risk transactions and activities in various sectors within the economy. The UAEFIU communicated the use and
mandate of each new report type to all reporting entities via notices or circulars sent through the goAML Message
Board. Comparisons between the types of goAML reports in 2020-21 follow.

2020 2021 Report Name Description

Suspicious transaction with details of bank

STR STR Suspicious Transaction Report
accounts/statements

Suspicious activities without the bank account/

SAR SAR Suspicious Activity Report
statement details

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

Partial name match to targeted financial

- PNMR Partial Name Match Report
sanctions lists

Dealers in Precious Metals and Stones Used for reporting cash transactions and Int'l wire
- DPMSR
Report transfers above AED 55,000 in the DPMS sector

- HRC High Risk Country Transaction Report

For transactions and activities related to FATF
High Risk Jurisdictions / Countries
- HRCA High Risk Country Activity Report

III. Domestic Cooperation Section

In 2021, DCS received 3525 requests for specific financial or non-financial information – 1204 on juridical persons and
3250 were on natural persons. The tables below illustrate the requests to DCS from relevant stakeholders.

Request Type Number

Provide a report including specific account review and analysis 129

Provide financial information from available databases within UAEFIU 717

Participate in joint investigative committee and interrogations meetings 16

Coordinate with foreign FIU for additional information 11

Provide specific information from financial institutions 1,870

Freezing of bank accounts: provide specific information 674

Request related to unfreezing of bank accounts 107

Other requests 1

Total 3,525

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 27

This second table represents the count of requests based on the case category.

Subject of Inquiry

Case Category Juridical Person Natural Person

Any proceeds resulting from a felony or misdemeanour 1 13

Armed Robbery 1

Corruption 6 6

Corruption and bribery 46 58

Counterfeiting currency 2

Drugs 29 36

Embezzlement of public funds 4 16

Environmental crime 1

Extortion 3

Forgery 1 1

Fraud 20 53

Fraud Cybercrime 3 10

Gambling 1

General Inquiry 186 239

Illicit arms trafficking 1

Illicit trafficking in narcotic drugs and psychotropic substances 27

Kidnapping, illegal restraint and hostage-taking 5

Money Laundering 833 2,493

National Security 1

No Financial Disclosure 2 6

Proliferation 29 25

Robbery or theft 2

Rogatory request 1

Sexual exploitation, including sexual exploitation of children 4

Smuggling (customs and excise duties and taxes) 2 5

Tax crimes (related to direct taxes and indirect taxes) 7 3

Terrorism Financing 6 33

Terrorism, including terrorist financing 21 158

Trafficking in human beings and migrant smuggling 27

Illegal money transfers 6 21

Total 1,204 3,250

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 28

Working with International Stakeholders cultural values, constitutional frameworks and legal
systems. Besides encouraging implementation of
The UAEFIU is actively involved with range of domestic,
FATF 40 Recommendations on AML/CFT and relevant
regional, and international partners. The UAE is a
UN treaties, agreements and UNSCRs, MENAFATF
member of MENAFATF which is a FATF-style regional
also works with other international and regional
body (FSRB). The UAEFIU has been a member of the
organisations, institutions and agencies to improve
Egmont Group of Financial Intelligence Units since
AML/CFT compliance worldwide.
5 June 2002.

Egmont Group
Financial Action Task Force (FATF)
The Egmont Group is a united body of 167 Financial
Established in 1989, FATF is an intergovernmental
Intelligence Units (FIUs), which provides a platform
organisation which develops international standards to
for the secure exchange of expertise and financial
curb ML/TF and counters the financing for weapons of
intelligence to combat ML/TF. This is especially
mass destruction. As the AML/CFT policy setter, FATF
relevant as FIUs are uniquely positioned to cooperate
monitors the progress of its members in implementing
and support national and international efforts to
necessary measures, reviews ML/TF techniques and
counter TF, and are a trusted gateway for sharing
countermeasures, and promotes the adoption and
financial information domestically and internationally
implementation of appropriate measures globally. In
in accordance with global AML/CFT standards.
collaboration with other international stakeholders,
FATF works to identify national level vulnerabilities
International Monetary Fund (IMF)
with the aim of protecting the international financial
system from misuse. The International Monetary Fund (IMF) comprises
190 countries, working to foster global monetary
FATF reviews ML/TF techniques and continuously cooperation, secure financial stability, facilitate
strengthens its standards to address new risks, such international trade, promote high employment and
as the regulation of virtual assets, which have spread sustainable economic growth, and reduce poverty
as cryptocurrencies to gain popularity. FATF monitors around the world.
countries to ensure that they implement the FATF
Standards fully and effectively, and holds countries Its primary mission is to ensure the stability of the
that do not comply to account. international monetary system — the system of
exchange rates and international payments that
Middle East and North Africa Financial Action Task enables countries and their citizens to transact with
Force (MENAFATF) one another. The Fund’s mandate was updated in 2012
to include all macroeconomic and financial sector issues
MENAFATF was formed as a FATF-Style Regional
that affect global stability.
Body (FSRB) at an inaugural Ministerial Meeting on
30 November 2004 in Manama, Kingdom of Bahrain,
The United Nations Office on Drugs and Crime
where the MENAFATF headquarters resides. It is
(UNODC)
voluntary and co-operative, and independent from any
other international body or organisation, established The UNODC is a global leader in the fight against
by agreement between its members’ governments, and illicit drugs and international crime, in addition to
not based on an international treaty. its responsibility to implementing the UN’s anti-
terrorism programme. Established in 1997, UNODC
MENAFATF recognises the threat posed by ML/TF has approximately 500 staff members worldwide. Its
operations to countries in the MENA region, and seeks headquarters are in Vienna; it operates 20 field offices,
to tackle these threats through co-operation between plus liaison offices in New York and Brussels.
MENA nations. It sets its own work, regulations,
rules and procedures, and co-operates with other UNODC works to educate the world population
international bodies, notably FATF, to achieve its on the dangers of drug abuse, and to strengthen
objectives. international action against illicit drug production and
trafficking and drug-related crime. To achieve those
MENAFATF countries work jointly to comply with aims, UNODC initiatives include alternatives to illicit
FATF standards and other measures adopted by drug crop cultivation, monitoring illicit crops and the
Arab States to combat ML/TF, aiming to establish an implementation of AML projects.
effective system which does not contradict existing

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 29

Glossary
Term Description

ADGM Abu Dhabi Global Market

AIF Additional Information File without Transactions

AIFT Additional Information File with Transactions

AML / CFT Anti Money Laundering / Countering Financing of Terrorism

AMLSCU Anti Money Laundering and Suspicious Cases Unit

CBUAE The Central Bank of the UAE

CFT Combatting the Financing of Terrorism and Illegal Organizations

CFZ Commercial Free Zones

CISD Inward Spontaneous Dissemination Case

DFSA Dubai Financial Services Authority

DNFBPs Designated Non-Financial Businesses and Professions

DPMS Dealers in Precious Metals and Stones

DPMSR Dealers in Precious Metals and Stones Report

Egmont Egmont Group of Financial Intelligence

ESW Egmont Secure Web

FATF Financial Action Task Force

FFR Funds Freeze Report

FFZ Financial Free Zones

FI Financial Institutions

FIU Financial Intelligence Unit

FSRA ADGM's Financial Services Regulatory Authority (FSRA)

GoAML The Financial Intelligence Unit's Online Reporting Application

HRC High Risk Country Transaction Report

HRCA High Risk Country Activity Report

IA Insurance Authority

IDR Inward Dissemination Request

IEMS Integrated Enquiry Management System

IRC Inward Request for Information Case

IRI Inward Request for Information

ISD Inward Spontaneous Dissemination

LEA Law Enforcement Authorities

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 30

Term Description

MENAFATF Middle East and North Africa Financial Action Task Force

MLRO Money Laundering Reporting Officer

MOE Ministry of Economy

MOFAIC Ministry of Foreign Affairs and International Cooperation

MoI Ministry of Interior

MOJ Ministry of Justice

MoU Memorandum of Understanding

MSB Money Services Business

National Committee for Anti Money Laundering and Combating the Financing of
NAMLCFTC
Terrorism and Financing of Illegal Organizations

NAP National Action Plan

ODR Outward Dissemination Request

ORC Outward Request for Information Case

ORI Outward Request for Information

OSC Outward Spontaneous Dissemination Case

OSD Outward Spontaneous Dissemination

PNMR Partial Name Match Report

PP Public Prosecution

PSTR Postponement of Suspicious Transaction Report

RE Reporting Entities

RFI Request For Information without Transactions

RFIT Request for Information with Transactions

RFR Reason for Reporting

SAR Suspicious Activity Report

SCA Securities and Commodities Authority

SP Supervisory Body (Regulator)

SS State Security

STC Suspicious Reports Case

STR Suspicious Transaction Report

TBML Trade-Based Money Laundering

TF Terrorism Financing

UAERRS UAE Remittance Reporting System

UNODC United Nations Office on Drugs and Crime

UAE FINANCIAL INTELLIGENCE UNIT (UAE FIU) AN N UA L R EPORT 2021 31