In an era where financial crimes increasingly threaten global stability and security, nations must continuously evolve their frameworks to combat these ever-changing threats. The United Arab Emirates (UAE) recognises this imperative and has issued its second National Strategy for AML/CFT/CFP for the period 2024-27, approved by the UAE Cabinet earlier this year. More than a mere update to the 2020-23 strategy, it represents a comprehensive and forward-thinking whole-of-government approach designed to boost the UAE’s capabilities for combating financial crime, in collaboration with our international partners, in order to strengthen our country’s position as an international financial centre and a global hub for trade and investment.
The strategy is an integral part of the UAE’s ongoing commitment to strengthening its legal and institutional frameworks that form the backbone of its national AML/CFT system. Under the stewardship of Sheikh Abdullah bin Zayed Al Nahyan, Deputy Prime Minister and Minister of Foreign Affairs, the Higher Committee for the Oversight of the National Strategy is charged with its issuance, while the National Committee for Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations will ensure its implementation. These bodies were established with enhanced roles and responsibilities by Federal Decree in August 2024, a testament to the UAE’s unwavering dedication to advancing its legal framework and ensuring strict compliance with international standards.
One of the most remarkable aspects of the 2024-27 Strategy is its continuity with, and expansion upon, the achievements of the 2020-2023 National Strategy. This new strategy is not just about maintaining momentum; it is about building on past successes while adapting to new and emerging threats and it will guide efforts leading up to the Financial Action Task Force’s (FATF) Mutual Evaluation Report in 2026. The UAE’s financial architecture has already seen significant improvements under the previous strategy, as evidenced by the nation’s compliance with 39 of the FATF’s 40 Recommendations and its ranking among the top five countries for asset recovery by the Global Coalition for the Fight Against Financial Crime.
The 2024-27 Strategy takes these achievements a step further by focusing on 11 strategic goals and numerous sub-goals that address the dynamic nature of financial crimes. It prioritises maintaining a robust and adaptable AML/CFT/CPF framework capable of tackling emerging threats such as virtual assets and cybercrime. These global challenges are becoming increasingly prevalent as technology advances, making it crucial for any effective strategy to be flexible and forward-looking.
UAE’s financial strategy strengthens resilience
The UAE’s approach is deeply informed by its understanding of the risks it faces as the Strategy draws on findings from two National Risk Assessments, the second completed with the support of the World Bank Group. It reflects feedback from the FATF’s International Cooperation Review Group (ICRG) Joint Group’s Assessment Team and various stakeholders from across the private sector, gathered from March 2022 to February 2024.
Central to the Strategy is its focus on compliance, effectiveness, and sustainability. By centring its goals around these key pillars, the UAE is not only addressing the current landscape of financial crime but also ensuring that its AML/CFT/CPF system remains resilient, solid and effective in the face of future challenges. Furthermore, the Strategy employs a risk-based approach, which ensures that resources are concentrated where they can have the most significant impact. This whole-of-government action targets and prioritises complex financial crimes and key emerging risks, including those associated with fraud, virtual assets, new technologies like AI, cash-related products and services.
The UAE is a dynamic hub for innovation, trade and investment, and one of the world’s fastest-growing economies. The foundation of this is a safe, resilient, sustainable, and efficient financial system. In this regard, the significance of the UAE’s 2024-27 Strategy extends beyond mere compliance with international standards. It is a clear statement of the UAE’s efforts aimed at solidifying its status as a centre of financial excellence and reinforcing international competitiveness. It enhances the groundwork for a secure national economy, where both citizens and companies are protected from criminal activities, thus allowing prosperity to flourish in line with the National Vision 2031.
Furthermore, the UAE’s aspirations are not limited to its own borders. The Strategy is a bold declaration of the nation’s commitment to progress in alignment with the standards of full FATF members, aiming to enhance its role within international bodies dedicated to combating financial crime. By positioning itself as a model for other advanced countries, the UAE is not only securing its financial environment but also contributing to global efforts to combat financial crime.
A key pillar of the UAE’s approach is its strategic dialogue with the private sector, driven by the AML/CFT Partnership Forum (ACFP)—the first public-private collaboration of its kind in the MENA region. The private sector’s involvement in shaping the Strategy, through a consultative process, ensures the UAE strikes the right balance between robust compliance and business competitiveness. With a new law for sharing information between public and private sectors expected in 2025/26, the foundation for collaboration between the Financial Intelligence Unit, law enforcement, and other public sector entities will be significantly strengthened.
The success of this Strategy will hinge on our national talent pool—professionals with the expertise and skills to drive this agenda forward. To foster this, training initiatives through the Nafis Program and leading Emirati research centres have been established. These efforts aim to inspire the next generation of financial crime fighters and support their career growth across both the private and public sectors.
The UAE’s National AML/CFT/CPF Strategy 2024-27 is a strategic, forward-looking plan that builds on past successes while addressing the complex challenges of the future. Through this Strategy, the UAE is not only safeguarding its own financial system but also pursuing our aspirations to be a global leader in the fight against financial crime. As other nations grapple with the ever-evolving nature of financial threats, the UAE’s approach serves as a beacon of best practices, underscoring the importance of adaptability, collaboration, and sustained commitment to combating international financial crime and protecting the integrity of the global financial system.