KYC AML Guide: the Clock shows the average reeding time of the blog07 min Read


KYC AML Guide: the Clock shows the average reeding time of the blogJuly 10, 2024

Dubai Unlocked: What Dubai Leaks Mean for AML Compliance?

The “Dubai Unlocked” investigation reveals the urgency of the UAE’s efforts to tackle and detect money laundering. Based on data from the Center for Advanced Defense Studies and coordinated by OCCRP with over 70 media outlets, the investigation found that 200 people, including alleged criminals, politicians, PEPs, and sanctioned individuals, owned more than 1,000 properties in Dubai. This raises concerns about the effectiveness of the UAE’s anti-money laundering (AML) measures, especially when many properties are purchased in the owners’ real names, making it difficult to understand how they avoid this scrutiny. This blog will delve into the Dubai leaks and highlight important gaps in AML compliance in the UAE's financial sector.

M Abd'al Bari

Research Associate

We have seen the corrupt side of Dubai real estate owners before. In 2018, the biggest leak of property data in the UAE revealed PEP, sanctioned individuals, and many criminals worldwide owning real estate in Dubai. Analysis of another leak of property data in 2022 showed that Russian political elites and other convicted European white-collar criminals owned real estate in Dubai as of 2020.

What is Dubai Unlocked?

Known for its lavish lifestyle and modern atmosphere, the city attracts the rich and famous. But its lax regulations have sheltered alleged criminals, politically exposed persons (PEP), and sanctioned individuals looking to hide their money. Dubai Unlocked is a global investigation of real estate owners in Dubai. The collaborative work involving more than 70 journalists reveals the real property owners and focuses on AML compliance and financial transparency issues in the UAE. Nearly dozens of properties worth more than $600 million were owned by 20 billionaires and their family members.  From alleged Australian cocaine dealers to relatives of African dictators and several sanctioned Hezbollah financiers, the findings reveal just how open the city is to the world’s most disreputable figures

The owners were separated into different categories

  • Convicted and alleged criminals,
  • Political figures, and
  • People under sanctions

Politically exposed persons (PEPs), including members of West African presidential families implicated in corruption probes, find Dubai appealing due to its financial secrecy, lack of property taxes, and stable political environment. Despite international efforts to seize assets linked to figures like Teodorin Obiang and Marie Madeleine Mborantsuo, their properties in Dubai remain untouched, reflecting challenges in international asset recovery efforts.

Meanwhile, individuals sanctioned by the U.S. for ties to Hezbollah, such as Adham Husayn Tabaja, have exploited Dubai’s financial environment. Despite sanctions, Tabaja and others linked to Hezbollah have acquired multiple properties in Dubai, raising questions about the effectiveness of UAE’s sanctions enforcement and AML regulations in curbing illicit financial activities.

These cases highlight the AML compliance implications for Dubai, underscoring the need for stronger AML screening and financial transparency measures in the Dubai financial sector. The presence of sanctioned individuals and PEPs engaging in property transactions also suggests vulnerabilities in business AML services and AML Banking Compliance within the UAE

Why is Dubai a Hub for Money Laundering?

Dubai is a magnet for money laundering for many reasons

Lack of Extradition Treaties:

Until recently, the UAE had few extradition treaties, making it a haven for fugitives. Although cooperation with foreign authorities has improved, however, responses to extradition requests remain inconsistent.

Minimal Scrutiny on Funds:

Dubai’s real estate market is known for asking clients a few questions about the source of their money. Until 2022, real estate agents, brokers, and lawyers were not required to report large cash or cryptocurrency transactions. it highlights the gap between AML compliance and AML screening.

Attractive Property Market:

Dubai’s booming real estate market offers great investment opportunities. Property prices are rising allowing illicit money to be laundered and invested. It raises the financial transparency concerns in Dubai.

These factors, combined with Dubai’s lavish lifestyle, make it a hub for financial crime and money laundering. The implications of AML compliance are significant, highlighting the need for robust business AML services and reforms in the Dubai financial sector to address Dubai’s money laundering effectively.

Regulatory Reforms

Emirati authorities have tightened regulations in recent years, especially after the Financial Action Task Force (FATF) placed the country on a “gray list” in 2022 for failing to effectively combat illicit money flows. Following significant lobbying, the UAE was removed from the list in February, with FATF acknowledging “significant progress.”

However, experts warn that the move might be premature. Colin Powers from the Noria MENA Program notes that while recent reforms might have helped lift Dubai from the gray list, they haven’t fundamentally changed the nature of its real estate market, which remains attractive for storing wealth due to the ability to hide ownership behind trusts, holding companies, and foundations.

UAE anti-money laundering authorities report that since 2022, real estate agents, brokers, and corporate service providers have increased reporting of suspicious transactions, with fines imposed by regulators tripling. However, a December 2023 government report shows that suspicious transaction reports filed by realtors and brokers between mid-2020 and mid-2023 accounted for just 0.002 percent of total real estate transactions in 2022. Current reporting regulations only apply to property sales, leaving rental activities unmonitored.


UAE officials, including the interior and finance and justice ministries and Dubai police, did not respond to detailed questions about the operation’s findings but the country’s embassies in the U.K. and Norway affirmed their commitment to safeguard the integrity of the global financial system.

A Wake-Up Call

The Dubai Leaks reveal significant gaps in AML (Anti-Money Laundering) compliance efforts. They highlight weaknesses in AML screening and monitoring within Dubai’s financial sector, particularly in real estate transactions where individuals, including PEPs (Politically Exposed Persons), have been able to acquire properties without rigorous scrutiny of the source of their funds. This lack of transparency poses challenges for enforcing AML sanctions effectively. The leaks underscore the urgent need for Dubai to strengthen its AML regulations, improve UBO (Ultimate Beneficial Owner) disclosure, enhance financial transparency, and improve cooperation with international authorities to curb money laundering activities in the region’s booming real estate market.


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M Abd'al Bari
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Muhammed Abd'al Bari is a certified Research Professional of KYC/AML Guide. Connect with Muhammed on LinkedIn