The introduction of anti-money laundering (AML) legislation in the United Arab Emirates in 2002 significantly changed the legal and business landscape in the country. A draft law containing further measures was approved by the Federal National Council (FNC) in early May this year and is approaching enactment, which will bring further changes.
Money laundering was formally criminalized under the AML Law of 2002, but it had long been a crime to knowingly possess the proceeds of criminal activity, at least as regards criminal activity carried out in the UAE. Moreover, many techniques used to conceal the origins of funds (like forging documents) are themselves crimes under the UAE’s Penal Code.
Nevertheless, the law issued in 2002 was a major change. It defined and formally criminalized money laundering. Money laundering was defined as the handling of funds that resulted from criminal acts committed anywhere in the world. Therefore, a person who had committed no crime in the UAE could be subject to criminal prosecution.
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Charles Laubach is a partner at Afridi & Angell, a UAE-based law ﬁrm with ofﬁces in Abu Dhabi, Dubai and Sharjah.
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