What national ML vulnerabilities did the UAE identify in its second NRA?
The second NRA assessed national vulnerability across a defined set of criteria, including accessibility to reliable information and evidence, national ML combating ability, overall sectoral vulnerability, quality of adjudication, asset forfeiture framework, CDD framework, criminal investigation, criminal prosecution, cross-border and customs controls on cash, and reliability of financial records.
The candid findings sit in a handful of places. Rapid measures to seize or freeze proceeds face implementation challenges when the holder of funds changes, particularly when funds move between accounts. There is a need to amend the national legal framework to allow confiscation of criminal property and property of corresponding value after conviction and without requiring a criminal conviction.
Others are resource-led. Domestic cooperation on tracking, identifying, seizing and freezing funds in a timely manner needs improvement. International cooperation faces delays and procedural issues. Registrar capacity to verify beneficial ownership through on-site and off-site inspection needs assessment. Independent audit laws need broader application and improved monitoring.
Legal Reference (source document):
· UAE Money Laundering and Terrorist Financing National Risk Assessment, 2nd NRA (2024)
· National Anti-Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations Committee
Scope note: national vulnerability criteria are assessed on the same five-point scale as threats and sector risks.
Further reading: Independent AML audit requirements in the UAE
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