While a legal framework for combating money laundering exists in the UAE, it remains relatively untested. Hadef & Partners discuss the approach to Anti-Money Laundering (AML) in the UAE by way of:

• An exploration of the laws and regulations governing the framework to combat money laundering and to prevent terrorism financing in operation in the UAE;

• Considering the penalties and sanctions available to the authorities in the UAE for money laundering and terrorism financing crimes, including the more modern sanction of freezing the proceeds of crime;

• A brief comparison of the regime in the DIFC compared to that of the onshore jurisdiction.

Legal Background

Although various related provisions such as “concealment” and “fraud” were already included in Federal Law No. 3/1987, the UAE specifically criminalised “money laundering” in Federal Law No. 4/2002 (“Old AML”).