What role does organised crime play in money laundering risk in the UAE?
The UAE faces significant global ML risks involving professional launderers and foreign organised crime groups that use complex networks across multiple jurisdictions. The second NRA links organised crime laundering to drug trafficking, fraud, smuggling, foreign corruption and tax evasion, and describes these activities as generating substantial illicit proceeds.
The technique described in the case studies is layering through legal structures rather than through exotic instruments. One typology involved transit accounts, where internationally wired funds were deposited and then moved through multiple rapid transactions to several bank accounts, with complex payments used to purchase assets including manager cheques while some funds were wired onward to other jurisdictions.
Detection in the case studies came from a combination of financial intelligence and physical investigation. Authorities identified controllers and mules using wiretapping, remote device monitoring, GPS tracking, controlled delivery and undercover operations, alongside live facial recognition through public CCTV to link cash withdrawals, purchases and exports to individuals.
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: investigative techniques described here are those available to UAE authorities, not to reporting entities.
Further reading: White collar crime and organised financial crime
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