What the UAE’s AML Strategy Means for Boards and Compliance Leaders

At the launch of the UAE National Strategy for Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Counter Proliferation Financing (CPF) for 2024-2027, His Highness Sheikh Abdullah bin Zayed Al Nahyan stated,

‘‘The UAE is committed to staying ahead of emerging threats through continuous enhancement of our AML/CTF framework, ensuring our financial system remains safe, resilient, and efficient.”

This ambition has led to stronger laws, more assertive supervision and increased enforcement visibility, along with a clear expectation that both boards and senior management take demonstrable, outcomes focused, ownership of financial crime risk.

In turn, this has resulted in a significant change in accountability, governance, and operational expectations.

The UAE’s evolving AML framework, supported by new legislation, executive regulations and intensified supervisory engagement, places explicit responsibility on boards to ensure that financial crime risks are understood, governed, and actively challenged.

This means boards must move beyond mere oversight. Regulators now expect directors to:

• Understand the institution’s financial crime risk exposure in detail
• Challenge management assumptions and risk assessments
• Ensure adequate resourcing, systems and expertise
• Oversee escalation, reporting and remediation effectiveness

In short, “tone from the top” is no longer rhetorical—it must be evidenced.

The UAE continues to emphasise a risk-based approach, aligned with international standards:

Supervisors are focusing on questions such as:

• Is the risk assessment dynamic, data-driven  and sufficiently granular?
• Are controls proportionate to actual risk exposure?
• Are higher-risk areas subject to enhanced scrutiny?

For compliance leaders, frameworks must be well-designed and operationally effective. Documentation alone will not withstand regulatory challenge; outcomes will.

While AML risks remain central, the UAE’s broader financial crime strategy increasingly recognises the confluence of risks—particularly fraud, cyber-enabled crime, and virtual assets – into a broader focus on financial crime risks.  These link to the 2024 National Risk Assessment.

For example, fraud in general and payment diversion frauds, impersonation attacks, and crypto-related typologies, in particular, are no longer peripheral issues. They are at the heart of financial crime risks and are increasingly interwoven. 

Compliance leaders must therefore ensure that:

• Financial crime frameworks are integrated, not siloed
• Intelligence from fraud, cyber and AML functions is shared and analysed holistically
• Emerging risks are incorporated into risk assessments and training

Boards, in turn, must understand that financial crime risk is no longer confined to AML in the narrow sense—it is enterprise-wide.

The UAE has demonstrated a willingness to take action, through fines, public statements and supervisory interventions. At the same time, global enforcement trends continue to reinforce the personal and institutional consequences of failure.

For boards, the implication is clear: financial crime risk is not just a compliance issue; it is a strategic, reputational  and, potentially, existential risk.

In practice, this results in five key areas of focus for boards and for compliance functions:

1. Active Governance
   Boards must engage deeply with financial crime risk, asking probing questions and demanding clear, evidence-based answers.
2. Methodologically sound risk assessments
   Risk frameworks must be dynamic, data-led, and reflective of real exposure—not generic templates.
3. Operational Effectiveness
   Controls must work in practice, not just on paper. Testing and assurance are critical.
4. Integrated Financial Crime Frameworks
   AML, CTF, CPF, sanctions, fraud, and virtual assets, must be managed as an interconnected whole.
5. Culture and Accountability
   Institutions must foster a culture where financial crime risk is understood, owned, and escalated appropriately at all levels.

“The UAE’s proactive approach not only safeguards the integrity of the global financial system but also strengthens our position as a leading international financial center and trade hub.” His Highness Sheikh Abdullah bin Zayed Al Nahyan.

To explore these themes in detail, sign up to attend our complimentary webinar on 1 April, 4 – 4:45 pm GST where Bruce Viney focuses on the practical questions boards should be asking today.

Bruce has been working in financial services for nearly 40 years, 25 of these as a learning professional focusing on compliance for a wide range of financial services companies, mainly through the analysis, design, creation and implementation of global training programmes for Tier 1 Banks and FTSE 100 companies. He has been Global Head of Compliance Learning for such firms three times and has provided compliance learning consultancy to similar companies many times. 

Bruce has also provided compliance training and consultancy in other fields such as real estate, industrial supply chains, charities, payment services providers, gambling and casinos and many others.  

A former Director of Training for CISI, Bruce has extensive experience of compliance and financial services-related qualifications and qualified as a Chartered Accountant with Price Waterhouse (as it was then known).

Bruce provides excellent training events on compliance, with a specific focus on financial crime, including all aspects of anti-money laundering, anti-bribery and corruption, fraud and sanctions.