Understanding UAE Money Laundering Laws: A Comprehensive Guide for Financial Professionals

The United Arab Emirates (UAE) has established a robust legal framework to combat money laundering (ML) and the financing of terrorism (TF), reflecting its commitment to maintaining a stable and transparent financial system. This guide, tailored for financial professionals and those interested in understanding “Uae Money” regulations, delves into the key aspects of the UAE’s anti-money laundering (AML) regime. Based on expert legal analysis, we break down the essential laws, compliance requirements, and enforcement mechanisms that shape the financial landscape of the UAE.

I. The Legal Pillars of AML in the UAE

The UAE’s AML framework is primarily built upon several key pieces of legislation:

Federal Decree Law No. (20) of 2018 (as amended): This is the cornerstone AML Law, outlining the core prohibitions, definitions, and penalties related to money laundering, terrorism financing, and financing of illegal organizations. It sets the overarching legal structure for AML compliance in the UAE.
Cabinet Resolution No. (10) of 2019: This resolution serves as the implementing regulation for the AML Law, providing detailed operational guidelines and compliance requirements for various sectors. It clarifies the practical application of the AML Law.
Federal Penal Law No. 31 of 2021 (Penal Code): This law contains provisions that complement the AML Law, particularly in defining predicate offenses and outlining general criminal procedures.

These federal laws are further strengthened and implemented by various regulatory and supervisory authorities at both the federal and local levels. These authorities issue supplementary regulations, rules, and guidance, which carry legal weight and provide sector-specific AML directives.

II. Defining Money Laundering in the UAE Legal Context

To understand the scope of AML regulations related to “uae money”, it’s crucial to grasp the legal definition of money laundering in the UAE. The law defines it as wilfully committing any of the following acts with the knowledge that funds are derived from a predicate offense:

Transferring or Moving Proceeds: This includes any action aimed at concealing the illicit source of funds through financial transactions.
Concealing or Disguising the Nature of Proceeds: Actions that hide the true origin, location, or ownership of illicit funds.
Acquiring, Possessing, or Using Proceeds: Simply holding or utilizing funds known to be from illegal activities constitutes money laundering.
Assisting the Perpetrator: Helping someone who committed the predicate offense to evade legal consequences is also considered money laundering.

Key Definitions Clarified:

Funds: Broadly defined to include all types of assets and economic resources, whether tangible or intangible, movable or immovable, and in any form (including digital and crypto assets). This encompasses natural resources, legal documents, bonds, shares, and any income derived from assets.
Proceeds: Funds generated directly or indirectly from any felony or misdemeanor, including profits and economic interests, or funds converted from such illegal sources.
Transaction: Any disposal or use of funds or proceeds, covering a wide range of financial activities.

Important Note: A conviction for the underlying predicate offense is not required to establish money laundering. The key element is knowledge that the funds are linked to criminal activity. Suspicion alone is generally not sufficient for a conviction, but intention can be inferred from handling funds with the requisite knowledge.

III. Predicate Offenses: The Foundation of Money Laundering Charges

Predicate offenses are the underlying criminal activities that generate illicit funds, which are then laundered. In the UAE, a “Predicate Offense” is defined as any felony or misdemeanor punishable under UAE law, regardless of where the crime occurred. This expansive definition means that even crimes committed outside the UAE can be predicate offenses if they are also considered crimes within the UAE.

Examples of Predicate Offenses in the UAE context:

The UAE’s National Risk Assessment has identified the most prevalent predicate offenses linked to money laundering in the country:

Fraud, Counterfeiting, and Piracy: Activities involving deceptive practices, fake goods, and intellectual property theft.
Illicit Trafficking in Narcotics: Drug-related crimes, a significant global concern.
Professional Third-Party Money Laundering: Services offered by professionals to facilitate money laundering for others.

Furthermore, other significant ML threats include:

Tax Crimes: Tax evasion and related offenses, impacting both direct and indirect taxes.
Insider Trading and Market Manipulation: Financial crimes within capital markets.
Robbery or Theft: Traditional property crimes.
Illicit Arms: Illegal weapons trafficking.
Forgery and Smuggling: Including customs and excise duty evasion.

The inclusion of tax offenses as predicate offenses highlights the comprehensive nature of the UAE’s AML framework, ensuring that financial crimes across various sectors are addressed.

IV. Extraterritorial Reach of UAE AML Laws

The UAE’s AML jurisdiction extends beyond its geographical borders. Extraterritorial jurisdiction applies in situations where:

Acts Committed in the UAE: Any part of the money laundering act occurs within the UAE.
Result Realized or Intended in the UAE: Even if the act originates outside the UAE, if the intended or actual financial impact is within the UAE, jurisdiction applies.

Similarly, predicate offenses committed outside the UAE can fall under UAE jurisdiction if the act is punishable in both the UAE and the country where it occurred. This demonstrates the UAE’s commitment to international cooperation in combating cross-border financial crime.

V. Corporate Criminal Liability for Money Laundering

In the UAE, both individuals and corporate entities can be held criminally liable for money laundering offenses. Corporate liability arises when the illegal act is intentionally committed in the entity’s name or for its benefit. This means that companies can be prosecuted if their employees or representatives, acting on their behalf, engage in money laundering activities. This provision emphasizes the responsibility of businesses to implement robust AML compliance programs and ensure ethical conduct at all levels of operation when dealing with “uae money”.

VI. Investigating and Prosecuting Money Laundering Crimes

Several government authorities are involved in the investigation and prosecution of money laundering offenses in the UAE:

Police: Law enforcement agencies are responsible for the initial search, investigation, and evidence collection related to ML activities.
Public Prosecution: This body has broad investigatory powers, including the ability to monitor accounts, access records, and seize assets. They are also responsible for prosecuting ML offenses in court.
Financial Intelligence Unit (FIU) of the Central Bank of the UAE (CBUAE): The FIU plays a crucial role in receiving and analyzing suspicious transaction reports (STRs) and providing intelligence to law enforcement. It acts as a central hub for AML information.

The public prosecution and courts have the authority to seize or freeze suspicious funds or proceeds during investigations and trials, often without prior notification to the asset owner. This swift action is designed to prevent the further movement or dissipation of illicit funds.

Specialized AML courts are being established across the UAE, including in major Emirates like Abu Dhabi, Dubai, Sharjah, and Fujairah. These courts are designed to enhance judicial expertise in handling complex AML cases and expedite the enforcement of AML laws.

VII. Statute of Limitations and Penalties for Money Laundering

Crucially, there is no statute of limitations for prosecuting money laundering offenses in the UAE. This means that individuals and entities can be prosecuted for ML crimes regardless of how much time has passed since the offense was committed. This reflects the seriousness with which the UAE treats money laundering.

Penalties for Individuals:

For individuals convicted of money laundering (without aggravating factors), penalties include:

Imprisonment: Between one and ten years.
Fines: Between AED 100,000 and AED 5 million.
Or Both: The court can impose both imprisonment and a fine.

Penalties for Companies:

For corporate entities, the penalties are significantly higher:

Fines: Between AED 500,000 and AED 50 million.
Operational Restrictions: The court may prohibit the entity from operating for a specific period or even revoke its business license.

Aggravated Penalties:

More severe penalties, including temporary imprisonment and fines ranging from AED 300,000 to AED 10 million, can be imposed if the perpetrator:

Abuses Professional Position: Exploits their profession or authority to commit the crime.
Uses Non-Profit Organizations (NPOs): Channels funds through NPOs for illicit purposes.
Operates within a Criminal Group: Acts as part of an organized criminal enterprise.
Is a Repeat Offender: Has previously been convicted of similar offenses.

Deportation of Foreign Nationals:

Foreign nationals who receive custodial sentences for money laundering or other felonies under the AML Law will be deported from the UAE. For misdemeanors (crimes with sentences less than three years), deportation may be ordered at the court’s discretion.

Failure to Report Suspicious Transactions:

Failing to file a suspicious transaction report (STR), whether intentionally or due to gross negligence, carries penalties of imprisonment and/or fines between AED 100,000 and AED 1 million.

“Tipping Off” Offenses:

Warning or informing anyone that suspicious transactions are under review is a serious offense, punishable by at least one year of imprisonment and fines between AED 100,000 and AED 500,000. This provision is designed to protect the integrity of AML investigations.

Asset Confiscation:

Upon conviction, the court is mandated to confiscate:

Illicit Assets: Funds, proceeds, and instrumentalities used or intended for use in the crime.
Equivalent Value: If the original illicit assets cannot be confiscated, an equivalent amount from the perpetrator’s assets will be seized.

VIII. Civil Penalties and Asset Forfeiture

While the UAE AML Law primarily focuses on criminal penalties, it’s important to understand the civil aspects as well.

Civil Penalties:

Currently, the AML Law does not prescribe specific civil penalties. However, individuals or entities harmed by money laundering activities can pursue civil claims for compensation after a criminal conviction is finalized. Additionally, civil liability may arise for regulated entities that fail to comply with their AML obligations, even if they are not criminally prosecuted for money laundering itself.

Asset Forfeiture:

The UAE legal system has robust mechanisms for asset forfeiture, allowing the government to seize proceeds of crime. Key aspects include:

Mandatory Confiscation: Courts are required to confiscate funds, proceeds, and instrumentalities linked to money laundering upon criminal conviction.
Provisional Measures: The public prosecution and competent authorities can identify, track, seize, or freeze assets suspected of being involved in ML activities even before a conviction. They can also prohibit trading, prevent evasion of freezing orders, and impose travel bans on individuals holding such assets.
Central Bank Authority: The Governor of the CBUAE has specific authority to freeze funds held in financial institutions, highlighting the central bank’s role in AML enforcement related to “uae money” flows. However, this initial freeze is limited to seven business days unless extended by the courts or public prosecution.
International Cooperation: UAE judicial authorities can cooperate with foreign counterparts to facilitate asset confiscation, particularly based on reciprocity agreements or treaties.

Non-Conviction Based Forfeiture:

While generally a criminal conviction is required for asset forfeiture, there are exceptions. Suspicious proceeds can be frozen or seized pending investigation or trial. In certain cases, authorities can appoint a third party to manage seized assets and even sell them before a court judgment. In such instances, the sale proceeds are held by the UAE Treasury, with provisions to compensate legitimate claimants acting in good faith. The CBUAE Governor’s power to freeze suspicious funds for up to seven days also represents a form of non-conviction-based asset control.

IX. AML Compliance Requirements for Financial Institutions and Businesses

A wide range of institutions operating with “uae money” are subject to AML compliance requirements under UAE law. These obligations are primarily defined in the Cabinet Resolution and apply to:

Financial Institutions (FIs): This broad category includes banks, finance companies, exchange houses, money service businesses, insurance companies, fund managers, securities brokers, and virtual banking service providers.
Designated Non-Financial Businesses and Professions (DNFBPs): This includes auditors, accountants, lawyers, notaries, legal professionals (when conducting certain transactions), company and trust service providers, dealers in precious metals and stones, and real estate agents and brokers.
Virtual Asset Service Providers (VASPs): Entities involved in virtual asset exchange, transfer, custody, or financial services related to virtual assets.
Non-Profit Organizations (NPOs): NPOs are subject to specific AML obligations to prevent misuse for terrorism financing.

These regulations apply across the UAE, including its Emirates and free zones. Financial free zones like the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) have their own regulatory authorities (DFSA and FSRA, respectively) that administer federal AML legislation and issue their own detailed AML rules, which must be complied with in addition to federal law.

X. Types of Institutions Under AML Scrutiny

The UAE’s AML regime casts a wide net, encompassing various types of institutions dealing with “uae money”.

Financial Institutions (FIs) include:

Traditional Banking: Banks, finance companies, and similar institutions.
Money Service Businesses: Exchange houses, money transfer services (including Hawala systems).
Insurance Sector: Insurance companies, agencies, and brokers.
Investment Management: Fund and portfolio managers, securities and commodities brokers, investment advisors.
Virtual Banking: Providers of digital banking services.

Designated Non-Financial Businesses and Professions (DNFBPs) include:

Financial Professionals: Auditors and accountants.
Legal Sector: Lawyers, notaries, and other legal professionals (when involved in certain financial transactions like real estate deals or client money management).
Corporate Services: Company and trust service providers who assist in establishing or managing corporate structures.
Precious Metals and Stones Dealers: Businesses dealing in high-value commodities that can be used for money laundering.
Real Estate: Real estate agents and brokers involved in property transactions.

Virtual Asset Service Providers (VASPs): Entities engaged in activities related to virtual assets, including exchanges, transfers, custody, and participation in virtual asset offerings.

XI. Licensing and AML for Payment Services and Money Transmitters

Payment services and money transmitters operating with “uae money” are strictly regulated in the UAE.

Licensing Requirement: Stored value services, electronic payments, retail payment services, card schemes, and money or value transfer services (MVTS) are regulated activities requiring a license from the CBUAE.
AML Compliance: Licensed payment service providers and MVTS are subject to the Cabinet Resolution and comprehensive AML compliance requirements. Supervisory authorities ensure their adherence to AML/CTF controls.

XII. Digital Assets and AML Regulations

The UAE is proactively regulating digital assets and ensuring they are integrated into the AML framework.

VASPs Under AML: Virtual Asset Service Providers (VASPs) are fully subject to federal AML law and regulations imposed by their specific supervisory authorities.
Regulatory Framework for Crypto Assets: The Securities and Commodities Authority (SCA) has implemented regulations for crypto asset activities, covering promotion, issuance, custody, exchange operation, and fundraising platforms related to crypto assets in the UAE.
Dubai Virtual Asset Regulation: Dubai has established a dedicated regulatory framework for virtual assets through the Dubai Virtual Assets Regulation Authority (VARA). VARA licenses and regulates VASPs in Dubai (excluding the DIFC) and sets rules for virtual asset activities.
ADGM and DIFC Regulations: The ADGM and DIFC financial free zones have also developed specific regulations and guidance for virtual asset activities within their jurisdictions.

This comprehensive approach demonstrates the UAE’s commitment to managing risks associated with “uae money” in the digital asset space.

XIII. Specific AML Compliance Obligations for Regulated Institutions

Regulated entities in the UAE face a wide array of AML compliance obligations, designed to prevent and detect money laundering and terrorism financing related to “uae money”. These obligations include:

Risk Assessment: Identifying, assessing, and understanding ML/TF risks, including customer and enterprise-wide risk assessments.
Customer Due Diligence (CDD): Implementing CDD measures, including simplified, enhanced, and ongoing due diligence, to verify customer identities and understand the nature of their business.
Compliance Officer Appointment: Designating a qualified compliance officer responsible for overseeing AML efforts.
AML Program Development: Creating and implementing risk-based AML compliance policies, procedures, systems, and controls.
Risk-Based Approach: Adopting a risk-based approach to AML, applying enhanced measures for higher-risk situations.
Suspicious Transaction Reporting (STR): Implementing mechanisms to identify and report suspicious transactions to the FIU and cooperating with authorities.
UN Sanctions Compliance: Promptly implementing directives related to United Nations Security Council resolutions on sanctions.
Record Keeping: Maintaining accurate and comprehensive records of transactions and customer data.
Transaction Monitoring: Screening and monitoring transactions to detect suspicious activities.

XIV. Variations in AML Compliance Requirements

While core AML obligations are generally consistent across regulated entities in the UAE due to alignment with international standards, some variations exist:

MVTS Specific Obligations: Money Value Transfer Services (MVTS) have specific requirements, such as maintaining up-to-date agent lists for regulatory access.
NPO Requirements: Non-Profit Organizations (NPOs) must adhere to best practices for transparency, integrity, and use official financial channels, considering varying financial sector capacities in different countries.
VASP Specific CDD: Virtual Asset Service Providers (VASPs) have specific CDD thresholds for incidental transactions (AED 3,500) and must obtain and retain detailed originator and beneficiary data for virtual asset transfers. Financial Institutions also have similar obligations when handling virtual asset transfers for customers.
Jurisdictional Differences: Variations exist between federal laws and local regulations in financial free zones like DIFC and ADGM, reflecting tailored AML rules within these zones.

XV. Authorities Responsible for AML Compliance Examination and Enforcement

Several government bodies oversee AML compliance and enforcement related to “uae money” activities in the UAE:

Central Bank of the UAE (CBUAE): Regulates banks, finance companies, insurance companies, and payment service providers. The CBUAE’s AML and CFT Supervision Department examines licensed FIs, ensures compliance, and identifies emerging AML risks.
Securities and Commodities Authority (SCA): Regulates capital markets, listed companies, securities brokers, and related entities.
Ministry of Economy (MOE): Supervises DNFBPs at the federal level and in commercial free zones (excluding lawyers and notaries). The MOE’s AML Department develops regulations and ensures DNFBP compliance.
Financial Services Regulatory Authority (FSRA) – ADGM: Competent authority for AML/CFT compliance within the Abu Dhabi Global Market (ADGM).
Dubai Financial Services Authority (DFSA) – DIFC: Competent authority for AML/CFT in the Dubai International Financial Centre (DIFC).
Dubai Virtual Assets Regulatory Authority (VARA): Regulates and licenses the virtual asset sector in Dubai and free zones (excluding DIFC), coordinating with CBUAE and SCA.

These authorities conduct examinations, issue guidance, and enforce AML regulations within their respective jurisdictions and sectors.

XVI. Suspicious Activity Monitoring and Reporting (STR)

A cornerstone of the UAE’s AML regime is the requirement for regulated entities to monitor and report suspicious activity related to “uae money”.

STR Obligation: FIs, DNFBPs, and VASPs are legally obligated to report to the FIU if they suspect or have reasonable grounds to suspect that transactions or funds are linked to criminal proceeds or activities, regardless of the transaction value. Failure to report can result in penalties.
goAML Platform: Reporting entities must register on the UAE’s goAML platform to file STRs directly to the FIU. Separate registration is required for each jurisdiction of operation (e.g., mainland, DIFC, ADGM).
Reporting Triggers: Reports are required for transactions, attempted transactions, activities, or funds that are suspected to be proceeds of crime, related to a crime, or intended for criminal use.
Reporting Process: The FIU provides detailed guidance on STR reporting, including required information such as reasons for reporting, transaction details, and involved parties.
Reporting Timelines: The CBUAE mandates FIs to file STRs within 35 days of initial suspicion, including a 20-day internal investigation period.
Defensive SARs Discouraged: The CBUAE cautions against filing “defensive SARs” solely to avoid penalties, emphasizing the need for genuine suspicion.
No Active Consent Process: There is no mechanism to seek active consent from authorities to proceed with suspicious transactions in the UAE.

XVII. Confidentiality Requirements for Suspicious Activity Reporting

Confidentiality is paramount in the STR process to protect the integrity of AML investigations and the reputation of individuals and entities involved with “uae money”.

FIU Database Security: The FIU maintains a secure, private database for STR information with strict confidentiality and access controls.
Limited Disclosure: Information related to STRs and AML investigations is confidential and can only be disclosed when necessary for investigations, legal proceedings, or AML Law violation cases. This includes both the report itself and the fact that a report was filed.
Data Protection Measures: Regulated entities must implement reasonable measures to protect STR information from unauthorized access.
Intra-Group Information Sharing: Sharing STR-related information within an organization or group (parent company, branches, subsidiaries) is permitted for AML/CFT purposes.
“Tipping Off” Prohibition: Directly or indirectly warning a customer or third party about an STR or AML review is a criminal offense.
Exemptions for Legal Professionals: Attorneys, notaries, and certain legal professionals are exempt from reporting suspicious transactions when information is protected by professional confidentiality.
Customer Confidentiality Not a Barrier: Regulated persons cannot refuse to file STRs based on customer confidentiality or data privacy concerns.

XVIII. Large Currency Transaction Reporting

While there are no specific requirements to report large currency transactions solely based on their size under the AML Law or Cabinet Resolution, large transactions involving “uae money” can be a red flag for money laundering. In the absence of a legitimate explanation, large transactions may trigger suspicion and the need for an STR. All suspicious transactions, regardless of amount, must be reported.

XIX. Cross-Border Transaction Reporting

Reporting requirements exist for cross-border movements of “uae money” and other valuables:

Declaration Requirement: Individuals entering or leaving the UAE with currency, bearer negotiable instruments, or precious metals/stones valued over AED 60,000 must declare it to customs authorities and provide accurate information upon request.
Suspicious Cross-Border Transactions: Regulated entities must report cross-border transactions to the FIU if there are reasonable grounds to suspect they are linked to criminal activity.
Enhanced Due Diligence for High-Risk Countries: Transactions involving individuals or entities from high-risk countries may trigger enhanced due diligence (EDD) measures.

XX. Financial Intelligence Unit (FIU) Role in AML Analysis

The FIU of the CBUAE is the central agency responsible for analyzing AML information and intelligence related to “uae money”.

Independent Body: The FIU operates independently to analyze ML/TF-related information.
Collaboration and Partnerships: The FIU actively engages in collaboration with local, regional, and international stakeholders, including other FIUs globally.
Key Responsibilities:
- Receiving and analyzing STRs from FIs and DNFBPs.
- Requesting further information from reporting entities and relevant authorities.
- Exchanging STR-related information with international counterparts.
- Providing analyzed intelligence and data to UAE law enforcement agencies for further investigation and action.

XXI. Penalties for AML Rule Non-Compliance

Failing to comply with AML rules in the UAE carries both civil and criminal penalties, underscoring the seriousness of AML compliance concerning “uae money”.

Administrative Penalties:

Competent or Supervisory Authorities can impose administrative penalties on regulated entities, including:

Written Warnings.
Fines: Ranging from AED 50,000 to AED 5 million per violation.
Restrictions on Sector Work: Limits on individuals working in regulated sectors.
Managerial Actions: Arresting responsible managers, board members, or executives, appointing temporary controllers, or restricting powers of management.
License Revocation: Revoking an organization’s operating license.
Corrective Action Requests: Requiring regular reports on measures to rectify violations.

Cabinet Resolution No. 16 of 2021 introduced additional administrative penalties for DNFBPs, including specific fines for failing to provide requested information to the FIU or failing to provide AML training to employees.

Criminal Penalties:

Criminal consequences for AML non-compliance can arise in aggravated circumstances, such as when:

Abuse of Professional Position: The perpetrator misuses their professional role.
NPO Involvement: The crime involves non-profit organizations.
Organized Crime: The crime is committed by a criminal group.
Repeat Offending: The entity or individual is a repeat offender.

Criminal penalties also apply for specific AML breaches, including:

Failure to File STR: Imprisonment and/or fines (AED 100,000 – AED 1 million) for intentional or grossly negligent failure to report suspicious transactions.
“Tipping Off”: Imprisonment (at least one year) and fines (AED 100,000 – AED 500,000) for warning or revealing ongoing AML reviews.

XXII. AML Compliance Personnel and Individual Liability

Compliance personnel, such as compliance officers and Money Laundering Reporting Officers (MLROs), play a critical role in the UAE’s AML framework related to “uae money”. They are subject to AML rules and can face enforcement actions for violations.

Compliance Officer Responsibilities:

FIs and DNFBPs must appoint compliance officers responsible for:

Reviewing suspicious transactions and deciding on STR filing.
Developing and implementing internal AML/CFT programs.
Reporting compliance levels to senior management and supervisory authorities.
Fostering a compliance culture and ensuring staff training.
Cooperating with supervisory authorities and the FIU.

MLROs in DIFC/ADGM:

In DIFC and ADGM, Relevant Persons appoint MLROs with similar responsibilities to compliance officers in mainland UAE.

Individual Liability:

The UAE AML framework includes personal liability for compliance officers and MLROs who fail to fulfill their duties. Enforcement actions against individuals can include warnings, fines, imprisonment, and bans from working in the regulated sector.

XXIII. Statute of Limitations for AML Rule Violations

There is no statute of limitations specified in the Cabinet Resolution for violations of AML rules. This means that entities and individuals can be held accountable for AML compliance failures regardless of when the violation occurred.

XXIV. Beneficial Ownership Registry in the UAE

Transparency of beneficial ownership is a key aspect of AML efforts related to “uae money”. The UAE has implemented regulations for beneficial ownership registration.

Cabinet Resolution No. 58 of 2020: Requires UAE-registered entities (including commercial free zones, excluding financial free zones like DIFC/ADGM) to obtain and maintain accurate and updated information on their Ultimate Beneficial Owners (UBOs).
Information Submission: Entities must provide UBO information to their licensing authority within 15 days of any changes.
Local Licensing Authorities: Local authorities (e.g., International Freezone Authority, Dubai DED) maintain this UBO information.
Non-Public Register (Generally): UBO information is generally not publicly accessible. Disclosure requires written approval from the beneficiary or is limited to specific legal exceptions.
DIFC and ADGM Regulations: Separate UBO registration obligations exist within the DIFC and ADGM financial free zones under their respective regulations.

This beneficial ownership framework enhances transparency and helps prevent the misuse of corporate structures for illicit financial activities involving “uae money”.

Disclaimer: This guide provides a general overview of UAE AML laws and regulations as of the latest available information. It is not legal advice and should not be substituted for professional legal counsel. For specific legal advice, consult with qualified legal professionals specializing in UAE AML law.