Date of Defense
12-11-2025 10:10 AM
Location
H1-1116
Document Type
Thesis Defense
Degree Name
Master of Governance and Public Policy
College
CHSS
Department
Government and Society
First Advisor
Dr. Abdulfattah Yaghi
Keywords
Anti-Money Laundering, Combating the Financing of Terrorism, Financial Action Task Force, Financial Information Unit, United Arab Emirates.
Abstract
This thesis presents an analysis of the UAE's role in developing anti-money laundering and counter-terrorism financing strategies at the local, regional, and international levels, focusing on a key problem: whether current strategies are sufficient to address the complexities of financial crimes in the digital age and how their effectiveness can be improved. The study relies on a descriptive analytical approach that includes an analysis of official documents, legislation, and reports at the national and international levels, in addition to a chronological tracing of the country's policies from 2002 to 2025, and an institutional comparison across the three levels (local/regional/international). The study also uses two theoretical frameworks: agency theory to understand governance gaps between stakeholders, and game theory to strategically analyze criminals' interactions with regulatory authorities, while including measurable performance indicators. The study reaches key findings. Domestically, the UAE has adopted an increasingly robust legislative and regulatory approach, starting with Law 2002 and continuing through Decree 20/2018 and subsequent amendments. This is supported by a set of executive regulations and sectoral decisions related to high-risk activities, such as real estate, gold, remittances, and virtual asset service providers, in addition to an updated beneficial ownership registry. An integrated governance structure is also in place, encompassing multi-level committees, including a Supreme Committee, a National Committee, an Executive Office, a Financial Intelligence Unit, and subcommittees. The modern National Strategy 2024–2027 focuses on a risk-based approach, enhancing smart oversight, fostering international cooperation, and capacity building, in addition to digital transformation through goAML and advanced analytics. Results indicate a clear improvement in compliance and reputation, which contributed to the country's removal from the grey list. Performance indicators include the quality of suspicious transaction reports, the efficiency of referrals, convictions, and confiscations, as well as the integration of information exchange at the internal and external levels. The letter highlights the UAE's support for cooperation through several active regional agreements and memberships. At the international level, the UAE's strategy aligns with the Financial Action Task Force (FATF) standards, UN frameworks, and information-sharing networks, with the UAE contributing technically and practically by disseminating practices and platforms that enhance enforceability. The study also identifies remaining gaps, including disparities in awareness and compliance among some non-financial businesses and professions, coordination in free zones, the risks of emerging technologies, and deeper skill enhancement. The study recommends several practical recommendations, such as expanding risk-based supervision to include complex value chains, integrating databases and beneficial ownership using artificial intelligence models to identify patterns, and strengthening professional accreditation and training programs for regulatory authorities and the private sector. Overall, the message emphasizes that the UAE has established an integrated and resilient system that has proven effective, but it needs to accelerate the digitalization of supervision, standardize compliance, and enhance cross-border cooperation to ensure sustainable preparedness against technology-driven financial crimes.
Included in
THE UAE'S ROLE IN DEVELOPING STRATEGIES TO COMBAT MONEY LAUNDERING AND TERRORISM AT THE LOCAL, REGIONAL, AND INTERNATIONAL LEVELS
H1-1116
This thesis presents an analysis of the UAE's role in developing anti-money laundering and counter-terrorism financing strategies at the local, regional, and international levels, focusing on a key problem: whether current strategies are sufficient to address the complexities of financial crimes in the digital age and how their effectiveness can be improved. The study relies on a descriptive analytical approach that includes an analysis of official documents, legislation, and reports at the national and international levels, in addition to a chronological tracing of the country's policies from 2002 to 2025, and an institutional comparison across the three levels (local/regional/international). The study also uses two theoretical frameworks: agency theory to understand governance gaps between stakeholders, and game theory to strategically analyze criminals' interactions with regulatory authorities, while including measurable performance indicators. The study reaches key findings. Domestically, the UAE has adopted an increasingly robust legislative and regulatory approach, starting with Law 2002 and continuing through Decree 20/2018 and subsequent amendments. This is supported by a set of executive regulations and sectoral decisions related to high-risk activities, such as real estate, gold, remittances, and virtual asset service providers, in addition to an updated beneficial ownership registry. An integrated governance structure is also in place, encompassing multi-level committees, including a Supreme Committee, a National Committee, an Executive Office, a Financial Intelligence Unit, and subcommittees. The modern National Strategy 2024–2027 focuses on a risk-based approach, enhancing smart oversight, fostering international cooperation, and capacity building, in addition to digital transformation through goAML and advanced analytics. Results indicate a clear improvement in compliance and reputation, which contributed to the country's removal from the grey list. Performance indicators include the quality of suspicious transaction reports, the efficiency of referrals, convictions, and confiscations, as well as the integration of information exchange at the internal and external levels. The letter highlights the UAE's support for cooperation through several active regional agreements and memberships. At the international level, the UAE's strategy aligns with the Financial Action Task Force (FATF) standards, UN frameworks, and information-sharing networks, with the UAE contributing technically and practically by disseminating practices and platforms that enhance enforceability. The study also identifies remaining gaps, including disparities in awareness and compliance among some non-financial businesses and professions, coordination in free zones, the risks of emerging technologies, and deeper skill enhancement. The study recommends several practical recommendations, such as expanding risk-based supervision to include complex value chains, integrating databases and beneficial ownership using artificial intelligence models to identify patterns, and strengthening professional accreditation and training programs for regulatory authorities and the private sector. Overall, the message emphasizes that the UAE has established an integrated and resilient system that has proven effective, but it needs to accelerate the digitalization of supervision, standardize compliance, and enhance cross-border cooperation to ensure sustainable preparedness against technology-driven financial crimes.