UAE’s 2025 ML/TF Risk Assessment

The Riffle

The UAE has released its second National Money Laundering and Terrorism Financing (ML/TF) Risk Assessment, offering a clear, data-backed picture of the country’s financial crime landscape. As one of the world’s leading business and financial hubs, the UAE acknowledges both its unique exposure to cross-border risks and its strong institutional ability to respond.

The Big Picture

• ML Risk: High

• TF Risk: Medium-High

• Primary Threats: Fraud, drug trafficking, smuggling, counterfeiting, tax evasion, foreign corruption

• High-Risk Sectors: Banking, Exchange Houses, Real Estate, Trade-Based Money Laundering (TBML), Virtual Assets, Dealers in Precious Metals and Stones (DPMS)

Despite these challenges, the UAE’s overall combating ability is rated high, reflecting robust legal frameworks, strong regulatory oversight, and active international cooperation 

Sectoral Spotlight

• Banking (Mainland): Medium-High risk, linked to PEPs and non-resident clients

• Exchange Houses: Medium-High due to heavy cash use and cross-border transfers

• Hawala Providers: High risk with weak controls

• Real Estate: Medium-High, tied to luxury property deals and foreign flows

• Virtual Assets: High risk, driven by anonymity and cybercrime vulnerabilities

In contrast, Financial Free Zones (DIFC and ADGM) show reduced vulnerabilities thanks to the absence of cash transactions and strong compliance cultures. Still, certain subsectors—such as brokers and investment managers—require ongoing supervisory vigilance 

Terrorism Financing

The NRA notes no domestic TF incidents, but vulnerabilities remain in:

• MVTS (Money Value Transfer Services): Frequently exploited in global TF cases

• NPOs: Exposed due to cross-border aid and operations in conflict zones

Emerging Risks

Luxury assets (yachts, cars) and potential casinos are flagged for future oversight. With over 828,000 legal persons registered in the UAE, beneficial ownership concealment remains a priority concern.

For Businesses -

The NRA is a call to action. Firms should:

• Refresh ML/TF risk assessments

• Strengthen controls on PEPs, VASPs, DPMS, and NPOs

• Enhance due diligence on cross-border transactions

• Monitor emerging DNFBP categories

Bottom Line: The UAE is making progress, but vigilance must keep pace with evolving risks.

Read our full briefing document presented by 10 Leaves here: