FATF Mutual Evaluation Scorecard
United Arab Emirates
UAE 2020 FATF Mutual Evaluation Report
Key Findings:
- Despite significant strides to improving its AML/CFT systems with the enactment of the AML Law in 2018 and AML By-Law in 2019, the enhancements were fairly recent, with the impact and effectiveness still not fully evident during the on-site visit.
- The National Risk Assessment (NRA) was a good starting point to understanding ML/TF risks, but it only provided a basic description of the ML issues within the jurisdiction. Issues identified were misaligned with the conclusions, as well as with the strategy.
- Law Enforcement Agencies (LEAs) need improvement on ensuring coherence of not routinely identifying and targeting crucial cases in line with the country’s risk profile, being a major international and regional financial centre, trading hub, and cash-intensive economy.
- Disparity of understanding and implementation of risk-based supervision amongst regulatory authorities.
UAE 2023 FATF Follow-Up Report and Technical Compliance Updates
Key Findings:
- The UAE issued revised Cabinet Resolutions in 2020, which primarily clarified the implementation and the obligation to freeze funds, not just the terrorist list implemented by the United Nations Security Council (UNSC), but also those locally listed. This effectively improved MER ratings for Recommendation 6 and Recommendation 7 in 2021.
- Administrative decisions were also issued in 2020 to address R25 deficiencies, imposing requirements related to endowments where trustees must disclose their status to financial institutions (FIs) and DNFBPs, which improved the Recommendation 25 rating.
- The UAE has taken steps to meet the new requirements of Recommendation 15, particularly around identifying and assessing ML/TF risks arising from new technologies, and from virtual asset (VA) activities and virtual asset service provider (VASP) operations. There are, however, some moderate deficiencies surrounding definitions, licensing, and the implementation of AML/CFT requirements.
- To address shortcomings on Recommendation 1, a national strategy was developed for 2020 to 2023 to deepen understanding of risks through multi-sectoral assessments, and to implement a national action plan focused on highest risk sectors.
- Legislative amendments were also implemented to adopt countermeasures based on risk levels, and for Financial Intelligence Units (FIUs) to conduct strategic analysis, improving ratings for Recommendation 19 and Recommendation 29.
Other FATF Mutual Evaluation Scorecards
Mexico
The scorecard tracks the Mexico 2018 FATF Mutual Evaluation Report and 2021 FATF Follow-Up Report and Technical Compliance Re-Rating Updates.
The Bahamas
The scorecard tracks the Bahamas 2017 FATF Mutual Evaluation Report and 2022 FATF Follow-Up Report and Technical Compliance Updates.
United States
The scorecard tracks the US 2016 FATF Mutual Evaluation Report and 2024 FATF Follow-Up Report and Technical Compliance Updates.
Canada
The scorecard tracks the Canada 2016 FATF Mutual Evaluation Report and 2021 FATF Follow-Up Report and Technical Compliance Updates.
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