Malak Abbas

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Recent Changes to FATF’s “Grey List”; Could the UAE be Next Off the List?

Between October 25 and October 27, 2023, the Financial Action Task Force (“FATF”), an international policy-making and standard-setting body dedicated to combating money laundering and terrorist financing, held its third plenary meeting of the year (the “October Plenary”), at which it made important updates to its list of jurisdictions under increased monitoring, often externally referred … Continue Reading

VARA’s Strict Application of its Virtual Assets and Related Activities Regulations 2023

The United Arab Emirates (“UAE”) has long been at the forefront of embracing technological and financial innovation.  For example, Dubai has emerged as a global hub for virtual assets (“VAs”) and cryptocurrencies.  Earlier this year, the Dubai Virtual Assets Regulatory Authority (“VARA”) adopted its first Virtual Assets and Related Activities Regulations 2023 (the “Regulations”), along … Continue Reading

United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosures of Potential Violations

Earlier this year, we published a post on the first Tri-Seal Compliance Note (“First Note”) issued by the United States Department of Justice’s (“DOJ”) National Security Division (“NSD”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).[1]  When issuing the First Note, … Continue Reading

Key Principles of Governance for Financial Institutions in The Kingdom of Saudi Arabia

The Saudi Central Bank (previously known as the Saudi Monetary Authority, or SAMA) has published the third edition of the Key Principles for Governance in Financial Institutions (the “Guide”), which are intended to enhance management styles, set direct and indirect strategic objectives, maintain stability, and promote the rights of stakeholders.… Continue Reading

The UAE Continues to Combat Bribery and Corruption

The United Arab Emirates (the “UAE”) continues to lead the Arab world in terms of its anti-bribery and corruption (“ABC”) endeavors. The UAE offers a business-friendly environment with an effective and efficient public administration; it criminalizes active and passive bribery, embezzlement, abuse of functions, and facilitation payments, it enforces its domestic ABC legislation and it … Continue Reading

Slavery in Supply Chains

 Squire Patton Boggs  has published its first edition of the Commodities & Shipping Group’s (CSG) Quarterly Update.  The topic we chose to focus on for this publication is  slavery in supply chains. The Global Survey Index reports over 45.8 million people are subject to modern slavery (26% of whom are children, and 55% are women … Continue Reading

Central Bank Guidance to UAE Financial Institutions Banking Cash-Intensive Businesses

The Central Bank of the UAE (“CBUAE”) has issued new guidance (the “Guidance”) to UAE financial institutions providing services to cash-intensive businesses. The specific characteristics of cash—anonymity, interchangeability, and transportability—make it an attractive medium for illicit actors seeking to obfuscate the proceeds of crime or the funding of terrorism.  Unlike other monetary instruments, such as … Continue Reading

New Central Bank Guidance for UAE Financial Institutions on Suspicious Activity/Transaction Reporting

On June 7, 2021, the UAE Central Bank issued new guidance requiring all UAE financial institutions to file suspicious activity reports (SARs) or suspicious transaction reports (STRs) with the UAE’s Financial Intelligence Unit (FIU) using the goAML portal within 35 calendar days of detection of any conduct that they reasonably suspect may be linked to … Continue Reading
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