On 23 February 2024 the Financial Action Task Force removed the United Arab Emirates from its list of
jurisdictions under increased monitoring, ending a listing that had run since March 2022.
Two things about that sentence are almost always reported wrongly, and one very large practical
consequence is almost always missed.
The UAE was never blacklisted
FATF maintains two separate statements, and conflating them is the most common error in coverage of
the FATF grey list.
| FATF’s actual term | What it means | Informal name |
|---|---|---|
| Jurisdictions Under Increased Monitoring | Jurisdictions with strategic deficiencies that “have committed to, or are actively working with, the FATF to address those deficiencies in accordance with an agreed upon timeline” | The “grey list” |
| High-Risk Jurisdictions Subject to a Call for Action | FATF “calls on all FATF members to apply enhanced due diligence, and, in the most serious cases, apply countermeasures” | The “blacklist” |
The UAE was on the first. It was never on the second. “Grey list” is not FATF’s own vocabulary at all —
it is shorthand the press applies to increased monitoring, and any account describing the UAE as
“blacklisted” is simply wrong about which document it was on.
It was not a UAE-specific decision
The February 2024 outcome removed four jurisdictions, not one. Barbados, Gibraltar,
Uganda and the United Arab Emirates all came off the list on the same day, while Kenya and Namibia were
added to it.
That detail is dropped from almost every retelling, and it changes the reading. This was a routine
plenary outcome in which several countries’ action plans were assessed together — not a bespoke
adjudication of the UAE.
On dates, a small honest caveat: the UAE’s Ministry of Foreign Affairs describes the announcement as
following plenary meetings held between 19 and 23 February in Paris, while FATF’s own publication is
titled for 21–23 February. Both are defensible — plenary week versus plenary sessions — so we are saying
“the February 2024 plenary in Paris” and leaving it there. For the same reason we give the original
listing as March 2022 without a specific day: FATF’s own site is unreachable to automated checking, and we
are not quoting a document we could not read.
What the UAE actually did
The action plan had 15 items. The Ministry of Foreign Affairs states that FATF
“announced the UAE’s completion of all 15 recommendations of its action plan, and has congratulated the
UAE on this achievement.”
Note the framing. The UAE’s own headline was “UAE successfully completes FATF recommendations” — it
does not use the phrase “grey list” anywhere. The completion was the claim; the removal was the
consequence.
The effort was chaired at the top. H.H. Sheikh Abdullah bin Zayed Al Nahyan, Minister of Foreign
Affairs, chairs the Higher Committee Overseeing the National Strategy on Anti-Money Laundering and
Countering the Financing of Terrorism, and attributed the result to “significant and distinguished efforts
by relevant ministries, the federal government and local entities.”
H.E. Hamed Al Zaabi, Director General of the Executive Office of Anti-Money Laundering and Counter
Terrorism Financing, was more forward-looking, naming the next tasks as “the completion of the national
risk assessment, formulation of national strategy for the upcoming years, and enhancement of our national
capabilities across public and private sectors.”
The consequence nobody tells businesses
Here is the practical point. Delisting did not reduce the compliance burden on UAE
businesses. The machinery built to get off the list is still running, and it is still issuing
instructions.
The Ministry of Economy and Tourism has continued issuing circulars to designated non-financial
businesses and professions after delisting — Circular No. 3 of 2024, Circular No. 4 of 2024 and
Circular No. 1 of 2025, each on updating the list of high-risk jurisdictions subject to a call for action
and jurisdictions under increased monitoring, and updating the counter-measures those businesses must
apply.
If your compliance file was last updated when the UAE came off the list, it is two years out of date.
Who this actually binds
The governing instrument is Federal Decree Law No. 20 of 2018 on Anti-Money Laundering and Combatting
the Financing of Terrorism and Financing of Illegal Organisations, together with its implementing
regulation.
The Ministry of Economy and Tourism is, in its own words, “the supervisory authority … entrusted with
the supervision of the ‘Designated Non-financial Businesses and Professions’ (DNFBPs) sector at the state
level and commercial free zones”, and has established a dedicated Anti-Money Laundering Department for
awareness, control and inspection.
DNFBPs are defined as non-financial sectors and activities most exposed to money-laundering risk given
the nature of their services or products. The sectors evidenced by the Ministry’s own published guidance
are:
| Sector | Ministry guidance published |
|---|---|
| Real estate | Risk-based approach guidance for the real estate sector |
| Trust and company service providers | FATF risk-based approach guidance |
| Dealers in precious metals and stones | FATF risk-based approach guidance |
| Auditors | Separate auditors legislation section alongside AML |
Every piece of that guidance is framed as a risk-based approach — the organising
principle of the whole regime. It is not a checklist you complete once; it is an assessment you are
expected to keep current.
Reporting runs through goAML, the platform launched by the Financial Intelligence Unit
of the Central Bank of the UAE and developed by the UN Office on Drugs and Crime. All financial
institutions and DNFBPs must register on it.
A dead link worth knowing about
One piece of housekeeping with real consequences: the Ministry of Economy is now the Ministry of
Economy and Tourism. The old economy.gov.ae domain no longer responds, and moec.gov.ae redirects
to moet.gov.ae.
A great deal of published compliance guidance — including guidance still being handed to new businesses
— points readers to the old address for goAML registration and DNFBP circulars. Those links go nowhere.
What it means now
For the UAE, the delisting removed a reputational overhang that had been cited in every conversation
about correspondent banking and cross-border flows since 2022. We are not attaching a number to that
effect, because every figure in circulation is a modelled estimate rather than a measurement.
For businesses here, the honest summary is that the country got off the list by building a supervisory
apparatus, and that apparatus did not go away when the listing did. Firms in real estate, corporate
services, precious metals and audit carry ongoing, updating obligations — and the sectors most affected
are precisely those our guides to
business setup and
opening a business
bank account deal with. Our comparison of
DIFC and ADGM
covers two jurisdictions with their own supervisory layers on top, our explainer on
Dubai’s crypto regulation under
VARA covers a sector built under exactly this scrutiny, and our reporting on
the Central
Bank’s view of the banking sector sets out the wider picture.
Primary sources: the UAE Ministry of Foreign Affairs’ statement of
23
February 2024, carrying the 15-recommendation completion and both officials’ quotes; the US Financial
Crimes Enforcement Network’s
reproduction
of the FATF outcome, which names the four jurisdictions removed and sets out FATF’s two list
definitions — cited because FATF’s own site refuses automated access; and the Ministry of Economy and
Tourism’s
anti-money laundering
page, carrying the DNFBP supervisory statement, the goAML link and the dated circulars.
