Subsequent to our article last week where we highlighted the steps being taken by the UAE to address its placement on the Financial Action Task Force (FATF) “grey list”, it seems there is no letting up – another announcement has been made by the UAE on 8th August 2022.
In its latest measures, the UAE has introduced new reporting requirements for certain real estate transactions. As part of the drive to improve its international standing on the AML/CTF stage, this latest requirement sees all real estate agents, brokers and law firms being required to file reports to the Financial Intelligence Unit (FIU) on the purchase and sale transactions of freehold properties that involve any one (or a combination of) three methods of payment, whether for a portion or the entire property value.
These are:
- Single or multiple cash payments equal to or above Dh55,000 ($14,976),
- Payments involving the use of a virtual asset, and
- Payments where the funds used in the transaction were derived from a virtual asset.
The new rules apply to both individuals and corporate entities that are party to the relevant real estate transactions, and also require real estate agents, brokers and law firms to obtain and record the identification documents of the parties to the applicable transaction.
It will of course, not go unnoticed that this latest move by the UAE happens to come about just days after the FATF issued its final guidance for the real estate markets. So on one hand, the UAE could be accused of playing to the orchestra, but on the other, compliance with the new FATF guidance would have been required at some point or another, so early steps towards compliance is no bad thing.
Given the existing flurry of AML/CTF compliance activity since being placed on the “grey” list, the UAE should be applauded for its efforts in bringing about a change to their AML/CTF regime so far, and in such a speedy manner. One does wonder though, if it is possible to achieve all of this so quickly, why wasn’t it done following receipt of the FATF warning in August 2020 which could have avoided the placement on the “grey” list altogether.
Anti-Financial Crime Support – How can Complyport Help?
Our experienced Financial Crime and Forensics team led by Martin Schofield—one of the world’s leading specialists in the field—brings a wealth of experience to every project we are engaged in. Our highly experienced financial crime professionals and forensic experts, in subjects such as anti-money laundering, counter terrorist financing, anti-bribery and corruption and fraud and regularly help our clients navigate the complexities of the financial crime and money laundering environment. Services offered by Complyport include:
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- Assistance in identifying Politically Exposed Persons (PEPs),
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- Expert Witness in Financial Crime cases
- Forensics and Investigations
- Design and/or delivery of online or face to face financial crime training
If this article has raised any questions, or you think your firm may require assistance, please contact either Martin Schofield via martin.schofield@complyport.co.uk or Jan Hagen via jan.hagen@complyport.co.uk to book in a free consultation.
About Complyport
Complyport is the City’s market leading consulting firm supporting the UK financial services industry for over 20 years. We specialise in providing Governance, Risk and Compliance services to support the regulated financial services industry to raise standards and thrive.
Complyport advises and assists firms to become authorised and to comply with the rules and requirements of regulators on an ongoing basis. Our vision is to be there for our clients every step of the way, helping them change, grow, and excel through expertise, insight, and innovation, and in so doing to become our clients’ most valued supplier and trusted advisor.
We have successfully assisted over 1000 firms to become authorised with the FCA and EU and are providing regulatory support to over 600 regulated firms on an ongoing basis globally. With presence in the UK and EU, as well as via our Associates Network, Complyport can assist firms across multiple jurisdictions.
Complyport’s multidisciplinary consultants possess deep expertise in their field, having acted in FCA skilled person reviews, as expert witnesses in legal cases and as expert investigators for firms or their legal advisers.
Day to day, we conduct audits and reviews of a firm’s products, processes, policies, and procedures to identify scope for business, to determine the impact of regulatory developments and to verify compliance with local regulations. Our clients tell us we live our values; we are driven, agile and collaborative.
