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Grey and black lists

Updated: Jan 2, 2022

Anti-Money Laundering regulations in the UAE

The Financial Action Task Force (FATF) identifies countries with anti-money laundering and combating the financing of terrorism (AML/CFT) deficiencies in two lists issued three times a year, the Grey list and the Black list.

UAE AML updates, MOE circular 09/AML/2021

The Grey list: Jurisdictions under Increased Monitoring

Jurisdictions under increased monitoring are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring.

The Black list: High-Risk Jurisdictions Subject to a Call for Action

High-risk jurisdictions have significant strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferation. Therefore, FATF calls on all members and urges all jurisdictions to apply enhanced due diligence, and, in the most serious cases, countries are called upon to apply counter-measures to protect the international financial system.

UAE's Business’s obligations

Reference to Circular Number: 09/AML/2021 dated 19 December 2021, issued by The Ministry of Economy of the UAE, non-financial entities (DNFBPs) obligations are as follows:

  • Regularly review the Grey and black lists

  • Take customer due diligence measures proportionate to risk posed from business relationships with natural or legal persons from Grey list countries.

  • Apply enhanced due diligence measures to all business relationships and transactions with

  • countries on the Blacklist, including natural and legal persons and those acting on their behalf,

  • Take the following countermeasures:

  • Do not establish a branch or representative office in the blacklisted countries

  • Monitor transactions and activities pertaining to blacklisted countries and report suspicious transactions.

  • Refrain from relying on third parties located in blacklisted countries to perform their due diligence procedures.

Who is subject to the AML/CFT regulations:

In addition to financial entities the following designated non-financial businesses and professions (DNFBPs) are subject to the AML/CFT regulations:

DNFBPs are entities who conduct the following activities and transactions:
  • All Registrars of companies in the UAE.

  • Real estate brokers and agents.

  • Dealers of precious metals and precious stones.

  • Auditing or accounting firms.

  • Corporate services providers.

  • Legal consultancy companies.

Access the Grey list here

Access the Black list here

Access the Circular 09/AML/2021 here

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