UAE Launches Third National Risk Assessment to Strengthen Financial Crime Controls

The UAE has launched its third National Risk Assessment, beginning a new nationwide review of money laundering, proliferation financing and other financial-crime risks that will help shape future supervisory and enforcement priorities.

The General Secretariat of the National Committee for Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Proliferation announced the assessment on 28 September. The exercise brings together 84 competent authorities as well as the private sector to update the country’s understanding of risks and determine where policy, supervisory and enforcement resources should be concentrated.

Hamid Saif Al Zaabi, Secretary-General and Vice Chair of the National Committee, said the assessment provides a foundation for policymaking and priority-setting. According to the official announcement, its findings are expected to help supervisory authorities develop risk-based supervision plans, assist law-enforcement agencies in directing resources and enable private-sector organisations to update institutional risk assessments and internal controls.

The scope is broad. The money-laundering component covers 21 predicate offences and more than 20 criminal typologies. Authorities will consider not only the number of cases but also the scale of illicit proceeds, connections to organised crime, international links, complexity and wider economic and social impact.

Proliferation-financing risks are also being assessed, including potential evasion of targeted financial sanctions. Authorities are examining risks involving commercial transactions, dual-use goods, corporate structures, intermediaries and methods that may conceal the parties involved.

The assessment also extends into areas increasingly relevant to financial institutions and technology companies. The official briefing said it covers licensed, unlicensed and emerging activities, illicit and cross-border financial flows, asset recovery, beneficial ownership transparency, misuse of legal persons and arrangements, virtual assets, complex ownership chains and new financing channels. Fraud typologies associated with modern technologies are also within scope.

The methodology has five stages: establishing scope and initial priorities; collecting data and evidence; analysing risks; validating findings against multiple sources; and translating the findings and identified data gaps into inputs for the 2028 National Strategy and National Action Plan.

The exercise builds on earlier assessments. The first was completed in 2018, while findings from the second were approved in 2024 and contributed to the UAE’s 2024–2027 National Strategy, which includes 11 strategic objectives, 50 sub-objectives and more than 250 initiatives.

For banks, exchange houses, insurers, corporate-service providers, virtual-asset firms and other regulated businesses, the assessment is significant because national risk findings can influence supervisory priorities and expectations around controls. The immediate message is that institutions should continue treating risk assessment as a dynamic process, particularly as financial products, technologies and cross-border transaction patterns evolve.