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Dubai Unlocked: Urgent need for enhanced oversight of UAE's anti-money laundering efforts

The Dubai Unlocked investigation reinforces the need for ongoing scrutiny of efforts by the United Arab Emirates (UAE) to prevent and detect dirty money being invested in the country, Transparency International said today. Authorities in the UAE should now investigate the revealed cases and take action if there is suspicion that properties were purchased with proceeds from corruption or other crimes.

The investigation is based on data obtained by the Center for Advanced Defense Studies, which was shared with E24 and the Organized Crime and Corruption Reporting Project (OCCRP) who then coordinated the project with over 70 media outlets from around the world. It has revealed that 200 people, including alleged criminals, fugitives, political figures, and sanctioned individuals, have owned more than 1,000 properties in Dubai.

As part of the investigation, OCCRP identified several politically exposed persons (PEPs) who have invested in Dubai real estate. In many cases, there seems to be discrepancies between their official sources of income and the value of their high-end properties. As PEPs, these individuals hold prominent public positions and are considered a high risk for potential involvement in bribery and corruption.

Even though real estate ownership is frequently disguised with the help of anonymous companies, in most of these newly reported cases, identified individuals had purchased properties in their own names. As authorities in the UAE are likely to hold this data themselves, it is difficult to understand how high-profile PEPs, including officials that are under investigation or subject to sanctions elsewhere, can purchase and own these properties without being subject to scrutiny. Authorities should be able to identify suspicious cases themselves, and also share intelligence with their foreign counterparts and target assets.

This isn’t the first time we’ve had a glimpse at the unscrupulous realm of Dubai real estate owners. In 2018, a major leak of property data in the UAE revealed numerous PEPs, sanctioned individuals and criminals from around the world who owned real estate in Dubai. In 2022, analysis of another leak of property data revealed that Russian political elites and convicted European white-collar criminals, among others, owned real estate in Dubai as of 2020.

Even after the information became publicly available, there is no evidence that the UAE authorities have targeted these suspicious assets. From a sample of 100 PEPs of interest named in the 2018 leak, Transparency International found that at least 58 still hold properties, despite not appearing to have official sources of income to justify such purchases, according to information available on the Dubai Land Department’s website.

These latest revelations come just a few months after the Financial Action Task Force removed the UAE from its so-called grey list, commending the country for making significant progress in addressing its money laundering issues. Following this removal, the European Parliament rejected the European Commission’s proposal to remove the UAE from the EU’s own anti-money laundering high-risk list.

Maíra Martini, Head of Policy & Advocacy (Interim), Transparency International, said:

"With numerous PEPs, and other shady people, still appearing to own property in the UAE unencumbered and uninvestigated, the country still has a long way to go in proving it's capable of diligently tackling financial crime. It is time for the UAE to demonstrate its commitment and close its doors to dirty money, identifying suspicious cases themselves and sharing intelligence with their foreign counterparts.

In the meantime, the international community must continue to put pressure on the UAE to ensure it effectively implements recent anti-money laundering reforms, supervises and sanctions those involved in enabling corruption and money laundering, and cooperates internationally on cross-border corruption cases."


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