The AML-CFT Law (Federal Decree-law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations) defines money laundering as engaging in any of the following acts wilfully, having knowledge that the funds are the proceeds of a felony or a misdemeanour

• Transferring or moving proceeds or conducting any transaction with the aim of concealing or disguising their illegal source
• Concealing or disguising the true nature, source or location of the proceeds as well as the method involving their disposition, movement, ownership of or rights with respect to said proceeds
• Acquiring, possessing or using proceeds upon receipt
• Assisting the perpetrator of the predicate offense to escape punishment

The crime of Money Laundering is considered an independent crime. The punishment of the perpetrator for the predicate offence shall not prevent his punishment for the crime of Money Laundering.

No. in order to be considered money laundering, it is not necessary for any of the stipulated acts to involve only money or monetary instruments per se, but any number of tangible or intangible assets such as, but not limited to:

• Funds bank or other financial accounts, including virtual or so-called crypto currencies
• Financial instruments or securities, such as shares, bonds, notes, commercial paper, promissory notes, IOUs, share warrants, options, rights (including land rights), or other transferrable securities or bearer negotiable instruments
• Contracts, loan instruments, titles, claims, insurance policies, or their assignment
• Intellectual property (including but not limited to patents or registered trademarks), royalties, licenses, or the rights thereto
• Physical property, including but not limited to commodities, land, precious metals and stones, motor vehicles or vessels, works of art, or any other goods exchanged as payment-in-kind

The AML-CFT Law defines the financing of terrorism as:

• Committing any act of money laundering, being aware that the proceeds are wholly or partly owned by a terrorist organisation or terrorist person or intended to finance a terrorist organisation, a terrorist person or a terrorism crime, even if it without the intention to conceal or disguise their illicit origin
• Providing, collecting, preparing or obtaining proceeds or facilitating their obtainment by others with intent to use them, or while knowing that such proceeds will be used in whole or in part for the commitment of a terrorist offense, or committing such acts on behalf of a terrorist organisation or a terrorist person while aware of their true background or purpose.

The AML-CFT Law defines the financing of illegal organisations as:

• Committing any act of money laundering, being aware that the proceeds are wholly or partly owned by an illegal organisation or by any person belonging to an illegal organisation or intended to finance such illegal organisation or any person belonging to it, even if without the intention to conceal or disguise their illicit origin.
• Providing, collecting, preparing, obtaining proceeds or facilitating their obtainment by others with intent to use such proceeds, or while knowing that such proceeds will be used in whole or in part for the benefit of an Illegal organisation or of any of its members, with knowledge of its true identity or purpose.

The Governor or his delegate shall have the right to freeze suspicious funds deposited at financial institutions for no more than (7) seven working days, in accordance with the rules and controls stipulated in the Implementing Regulation of the present Decree-Law, renewable by order of the public prosecutor or his delegate.

• Imprisonment and fine of no less than AED100,000 and no more than AED1,000,000; or
• Any of these two sanctions

• Imprisonment for no less than six months and a penalty of no less than AED100,000 and no more than AED500,000; or
• Any of these two sanctions.

Its purpose is to provide guidance and assistance to supervised institutions that are DNFBPs, in order to assist their better understanding and effective performance of their statutory obligations under the legal and regulatory framework in force in the UAE.

• Auditors and accountants
• Company and trust service providers
• Dealers in precious metals and stones
• Real estate agents and brokers
• Any other Designated Non-Financial Businesses and Professions (DNFBPs) not mentioned above

• Identifying and assessing ML/FT risks 
• Establishing, documenting, and updating policies and procedures to mitigate the identified ML/FT risks 
• Maintaining adequate risk-based customer due-diligence (CDD) and ongoing monitoring procedures 
• Identifying and reporting suspicious transactions 
• Putting in place an adequate governance framework for AML/CFT, including appointing an AML/CFT Compliance Officer, and ensuring adequate staff screening and training
• Maintaining adequate records 
• Complying with the directives of the Competent Authorities of the State in relation to the
• United Nations Security Council resolutions 

• Financial audits related to a client’s books, records, and annual and periodic accounts
• Operational audits related to a client’s internal controls, governance structures, and risk management processes and procedures
• Compliance audits related to a client’s adherence to legal and regulatory requirements.

• Brokers and real estate agents when they conclude operations for the benefit of their customers with respect to the purchase and sale of real estate

The goAML system is an integrated digital platform through which Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) can be submitted by financial institutions, designated non-financial businesses and professions, and the relevant authorities. The Financial Intelligence Unit uses it to quickly and efficiently receive, analyse and distribute suspicious transaction reports. It is currently used by a large number of financial information units worldwide, and the UAE is the first Gulf country to implement this modern system.

All Designated Non-Financial Businesses and Professions (DNFBPs) must register on the goAML portal. Please read your Trade/Commercial license and complete the DNFBP questionnaire on the MOE website to help determine if you are a DNFBP or not.

• The first stage is the registration in the protection system, Services Access Control Manager (SACM) of goAML portal.
• The second stage is the registration in the goAML system. 

To open the goAML portal, you need to pass through the SACM portal by putting the username that you will obtain from the registration stage of the SACM protection system and the password from the Google Authenticator application.

SACM can be accessed at the following link: https://eservices.centralbank.ae/sacm
Click here for more information on SACM.

• Authorisation letter from the institution you represent 
• A copy of your passport, resident VISA, Emirates ID
• A copy of the commercial trade license (for companies)

Download the "Google Authenticator" application on your phone. (This application contains the password for the SACM protection system, which is a password that changes every minute)

The activities mentioned in Cabinet Resolution No. 100 of 2020 are required to notify the Ministry. For more information, please visit the following website: https://mof.gov.ae/economic-substance-regulations-ar/. Headquarters operations.

 Shipping operations.

 Holding company operations.

 Intellectual property (IP) operations.

 Distribution or service center operations

There are no specific procedures, but companies are required to submit the notification if failed to do so.

Failure to provide notification will lead to an AED 20,000 fine.

For further details on fines and appeals under the Real Economic Activities Regulations, please visit the Federal Tax Authority web page on Real Economic Activities via the following link:

https://tax.gov.ae/ar/esr/economic.substance.regulations.aspx

https://tax.gov.ae/ar/esr/economic.substance.regulations.aspx

The Cabinet resolution is subject to the Commercial Registration Department - and the Anti-Money Laundering (AML) Department follows up on the implementation of the resolution.

Please send an email to the AML@economy.ae and the Anti-Money Laundering Department will respond to each email in due course. Please do not follow up even if the deadline for submission expires.

Please access the login instructions available on the Ministry of Economy website via the link:

https://www.moec.gov.ae/web/guest/aml

1. The company in violation will be notified by the Anti-Money Laundering Department via the e-mail provided, with details of the violation found, the fine amount and the link to the fine payment page of the Ministry.

2.The payment link is opened by the person in charge on the company’s side (recipient of the email).

3. Page entry is done by registering in the system (once).

4.The required fields (mentioned above) are filled to register, and the system can be accessed if the company is already registered.

5. The fine amount to be paid is selected from the list on the page.

6. Payment is done online using any of the payment methods available, and the receipt is issued digitally through the system with a reference number.

One working day. In case there is a payment error, you can contact technical support via eservices.support@economy.ae e-services.