Placement: In this stage, funds obtained through illegal activities are introduced to the financial system.
Layering: In this stage, money is moved through various bank accounts or transactions to create a distance between the source and destination of funds.
Integration: In this stage, the laundered money is integrated into the financial system and appears legal.
Money laundering is usually described in three stages. Placement is the point at which criminal proceeds first enter the financial system or are converted into another form, for example by depositing cash, buying an asset or paying it through a cash-intensive business. Layering follows, moving the funds through transfers, conversions, companies and jurisdictions so that the audit trail to the original crime becomes hard to follow. Integration is the final stage, where the funds re-emerge as apparently legitimate wealth, such as property, a business investment or a salary.
The stages are a description of typical behaviour, not a legal test. UAE law does not require proceeds to have passed through all three before an offence is committed. The offence covers conducting a transaction in funds knowing they are the proceeds of a felony or misdemeanour, with the intent to conceal or disguise their illicit origin, to conceal or disguise the truth about them, to acquire, possess or use them, or to assist an offender to escape punishment. A single act at any stage is enough.
· Cabinet Resolution No. 134 of 2025, Article 17, which requires each entity to establish and keep updating indicators for identifying suspicion, reflecting how methods of committing the crime develop.
For your own circumstances, check your internal AML policy or speak to your compliance officer.