What product and channel risks does the UAE NRA highlight?
The second National Risk Assessment highlights trade-based money laundering, complex and anonymous transactions, cash-intensive products, cross-border transfers, banknote shipments, prepaid cards, and new financial technology products that can result in anonymity. Delivery channel risk covers ATM cash deposit machines, electronic banking, wire transfers and remittances.
Cheque cashing facilities and payment processing services are named for banks specifically, alongside exposure to money transport and cash controller networks, proxy networks, money mule networks, and digital money and virtual currency networks.
The fraud typologies named are current rather than historic: impersonation fraud, business email compromise and pig butchering scams. A firm whose product risk assessment does not reflect those three is describing a threat picture that is several years out of date.
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: product and channel factors are drawn from sector findings across the NRA. Applicability depends on your own product set.
Further reading: Designing an AML/CFT control framework
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