Money Laundering or Hawala in the UAE: What are Red Flags in AML?

Money Laundering or Hawala in the UAE

Money laundering or Hawala in UAE is the common term used to refer to how offenders disguise the source of money. 

Money laundering and terrorist financing threaten economic stability and provide funds for illegal activities. Hence comprehensive anti-money laundering (AML) regulations are critical. The United Arab Emirates (UAE) has stringent AML regulations, and it’s vital that businesses and financial institutions operating in the country understand red flag indicators to detect suspicious transactions.

What is Money Laundering?

Money laundering involves concealing illicit funds’ illegal origins through complex financial transactions. The process enables criminals to utilize “dirty” proceeds of crimes by funneling them through legitimate businesses. It can lead to severe money laundering punishment in uae including hefty fines and imprisonment.

Common money laundering techniques include:

  • Structuring cash deposits to avoid reporting thresholds
  • Using shell companies or fronts to disguise ownership
  • Smurfing – making multiple small payments vs one large one
  • Trade-based money laundering via inflated invoices etc.

Left unchecked, money laundering destabilizes economies and enables terrorism, drug trafficking, corruption, tax evasion and other crimes.

AML Regulations in the UAE

The UAE prioritizes the fight against financial crimes. The key regulations include:

  • Federal Law No. 20 of 2018 on AML
  • Central Bank Anti-Money Laundering and Combating Financing of Terrorism and Illegal Organisation’s Regulation
  • Cabinet Resolution No. 38 of 2014 concerning Terrorist Lists Regulation
  • Other supporting resolutions and guidance from regulatory bodies like the Financial Intelligence Unit (FIU) and ministries

These regulations impose obligations around customer due diligence, record keeping, reporting suspicious transactions, implementing adequate compliance programs and more.

Failure to comply entails stern penalties including hefty fines of up to AED 5 million and even potential imprisonment.

What are Red Flags in AML?

Red flags refer to unusual indicators that signal potentially illegal activity requiring further investigation. Common AML red flags relate to:

Suspicious Customer Behavior

  • Secrecy about identity or unwillingness to provide information
  • Reluctance to provide details about nature and purpose of business
  • Frequent and unexplained changes in identifying information
  • Suspicious attempts to avoid reporting requirements

High-Risk Transactions

  • Significant cash payments without clear origin of funds
  • Transactions with entities in high-risk jurisdictions
  • Complex deal structures masking beneficial ownership
  • Abnormal size or frequency for customer profile

Unusual Circumstances

  • Transactions lacking reasonable explanation/economic rationale
  • Inconsistencies with customer’s usual activities
  • Unfamiliarity with details of transactions made on one’s behalf

Red Flags in UAE’s Context

The UAE faces specific money laundering risks from high cash circulation, gold trading, Real estate transactions etc. Some key red flags include:

Cash Transactions

  • Deposits, exchanges or withdrawals over AED 55,000
  • Multiple transactions below the threshold to avoid reporting
  • Purchases of cash instruments like travelers checks without travel plans
  • Suspected involvement in counterfeiting in UAE

Trade Finance

  • Customers displaying minimal concern about payments, commissions, trade documents, etc.
  • False reporting of commodity details and shipment routes
  • Significant discrepancies in import/export quantities or values

Real Estate

  • All-cash sales, especially via wire transfers from foreign banks
  • Transactions with legal entities whose ownership can’t be verified
  • Purchase prices inconsistent with valuation reports
  • Concurrent purchases and sales between related entities


  • Frequent cash purchases of high-value items for assumed resale
  • Reluctance to provide proof of origin of funds
  • Purchases/sales without profit margins despite dealer status

Company Formation

  • Individual from high-risk country looking to quickly establish local company
  • Confusion or reluctance to discuss details of planned activities
  • Requests to help conceal ownership structures

Actions in Response to Red Flags

Businesses should take reasonable measures upon detecting potential AML red flags:

Enhanced Due Diligence (EDD)

Gather further information about the customer, source of funds, nature of activities etc. Additional proof of ID may be mandated despite initial acceptance.

Review by Compliance Officer

The company’s AML compliance officer should assess the situation’s reasonableness and determine suitable actions.

Suspicious Transaction Reports (STRs)

If activity seems suspicious despite EDD, file an STR to the FIU within 30 days. STRs are required regardless of transaction value if money laundering is knowingly or reasonably suspected. Penalties apply for non-reporting.

Risk-Based Actions

Measures like enhanced monitoring, restricting activity, or exiting relationships may be considered depending on specific cases. However, tipping off subjects regarding filing of STRs is legally prohibited.

Importance of Ongoing Monitoring

With evolving money laundering and terrorist financing techniques, ongoing transaction monitoring and vigilance are crucial.

Steps like:

  • Reviewing new services/products for vulnerabilities
  • Updating customer risk classifications
  • Periodic evaluation of suspicious activity monitoring systems
  • Analyzing transactions against customer profiles
  • Comparing activities to peer or industry baselines
  • Automated monitoring of sanctions lists and PEPs

Enable proactive identification of red flags before issues multiply.


Understanding indicators of potential illicit activity is vital for AML compliance in the UAE. Red flags related to unusual customer behavior, suspicious transacting patterns, transaction sizes inconsistent with income levels, and other signs listed here should warrant further investigation.

While specific cases determine the appropriate actions, dismissing concerns out of hand can have serious consequences. Besides financial and reputational repercussions, the UAE’s stern AML regulations impose civil and criminal liability for non-compliance.

Hence it is essential for businesses to implement adequate controls and ensure staff are trained to recognize and respond appropriately to Red Flag Indicators in AML.

1 thought on “Money Laundering or Hawala in the UAE: What are Red Flags in AML?”

  1. Avatar for Colleen

    My husband has been stopped at Dubai Airport saying he is money laundering he was traveling with a large amount of money that he took out of a UK bank he tried to send some to me but the systems where down at the bank and could not do this and all the money he has is there with him.
    His daughter has just had a hart operation and will be discharged from hospital in the UK and will have no where to go to she is 13 year old .
    The officer’s at the airport say he needs to pay the amount of 5000Dollars but the officers have taken all his money.
    Please my husband is a good honest family man that wants to come home and bring his daughter here to South Africa
    What do we do now any bit if advice will help
    Thank you
    Colleen Lawson


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