Export Control & Combating Terrorist Financing

With the Arabian Gulf’s largest seaport and airport, the United Arab Emirates recognizes the need for extraordinary diligence on security. The UAE is committed to continually improving its own security—and that of its allies—by preventing illegal transshipments and money flows.

The UAE Strongly Supports and Fully Enforces UN Sanctions

The UAE has expressed its deep concerns about Iran’s nuclear activities. The Iran nuclear program is not transparent and has not adhered to international regulatory standards and agreements. The UAE fully supports and enforces UN resolutions barring shipment of sensitive materials and technologies to Iran.

A Stringent Export Control Law with Stiff Penalties

The UAE has tightened export control laws and enforcement to prevent the movement of illicit goods and materials across its borders. In August 2007, the UAE government enacted a stringent export control law that includes stiff penalties for parties involved in the diversion of controlled shipments.

To help implement this law, the UAE cabinet formed the UAE Committee on Commodities Subject to Import and Export Control, which includes representatives from across the UAE government. These measures are in line with the UAE’s vision of maintaining security and stability in the UAE and abroad.

Strong Enforcement Leads to Interdiction

As a result of the law, the UAE has shut down dozens of international and local companies involved in money laundering and proliferation of dual-use and dangerous materials banned under the Nonproliferation Treaty and multiple UN resolutions. UAE security forces have interdicted scores of ships suspected of carrying illicit cargo, based on intelligence from its own and third-country agencies.

The UAE Works with US Partners

The UAE and related agencies and companies are involved in bilateral and multilateral initiatives designed to enhance safety and control processes:

  • The UAE joined the Nonproliferation Treaty in 1996, is a member of the International Atomic Energy Agency, and cooperates with the Missile Technology Control Regime.
  • The UAE participates in the US Container Security Initiative (CSI), a security regime that includes a team of US Customs and Border Protection officers permanently stationed inside Dubai's ports, where they work closely with Dubai Customs to screen containers destined for the United States.
  • The UAE worked with the US Department of Energy to implement the Megaports Initiative, a multinational effort aimed at deterring terrorists from using the world's seaports to ship illicit materials; detecting nuclear or radioactive materials if shipped via sea cargo; and interdicting harmful materials so they cannot be used by terrorists.
  • The UAE is a signatory to the Arab Convention for the Suppression of Terrorism.
  • Ports operated by Dubai Ports World participate in the Security Freight Initiative, a US Department of Homeland Security pilot program to test the methods used to screen US-bound cargo for radiation.
  • The UAE is a signatory to the Proliferation Security Initiative (PSI), which is aimed at stopping shipments of weapons of mass destruction, their delivery systems, and related materials worldwide.
  • Dubai Ports World has been certified as a partner in the Customs-Trade Partnership Against Terrorism, a government-business cargo security initiative led by the US Department of Homeland Security.
  • The US Department of State, through its Export Control and Related Border Security Assistance program, is helping the UAE improve its enforcement and licensing capabilities aimed at curbing the transshipment of elicit materials.
  • The Joint UAE-US Financial Counterterrorism Task Force enhances cooperation, coordination and information sharing to shut down terrorist financing networks and cut off the flow of funds to extremists.
    • The Task Force helps block funding to extremists from individuals and commercial activity such as black market sales of oil, and prevents access to the international banking system.

The UAE Fights Terrorist Financing 

The UAE has frozen the accounts of known terrorists and enacted aggressive anti-money laundering initiatives. New counter-terrorist financing laws and regulations have been introduced and enforced. The UAE:

  • Committed to the International Convention on the Suppression of the Financing of Terrorism, in 2005
  • Ratified the UN Convention Against Transnational Organized Crime in 2007
  • Is a member of the Middle East and North Africa Financial Action Task Force (MENAFATF), which facilitates international cooperation against terrorist financing.
  • Belongs, through the Gulf Cooperation Council, to the Financial Action Task Force, which supports non-proliferation principles and enforcement.
  • Created a financial intelligence unit, an Anti-Money Laundering and Suspicious Cases Unit, and is a member of the Egmont Group of Financial Intelligence Units.
  • Enacted a law in 2018 to ensure compliance with international standards on anti-money laundering and countering terrorist financing policy.
    • The law implements frameworks for monitoring credit standing, disclosure, compliance and governance procedures in the operations of the Central Bank of the UAE, to ensure confidence in the national economy.
  • In 2021, the UAE established an Executive Office of Anti-Money Laundering and Counter Terrorism Financing. The Executive Office will oversee the implementation of the UAE’s national anti-money laundering and countering the financing of terrorism (AML/CFT) strategy, in close coordination with the Financial Action Task Force and other regional and global entities.

Enhanced Financial Monitoring 

  • The UAE supports strict enforcement of counter-terrorist financing laws and regulations, encouraging increased monitoring of charitable fundraising and further examination of money flows across the region.
  • The Central Bank conducts anti-money laundering (AML) training both locally and regionally, and has expanded its cooperation with foreign financial intelligence units.
  • During key periods of religious observance, the UAE government airs television commercials warning citizens and residents to refrain from donating money through unapproved channels, including religious centers, as the funds could unknowingly support terrorist causes.

Increased Government Capacity

  • The UAE judicial and financial systems have a number of mechanisms in place to freeze and confiscate terrorist assets and the assets of those suspected of terrorist financing. 
  • The State Security Court, a branch of the Federal Supreme Court, has increased its capacity to handle terrorist support cases, including trying cases against those suspected of illegally collecting money to finance a terrorist organization.

                                     What Others Are Saying

David. S Cohen, Acting Director of the Central Intelligence Agency; Former Under Secretary of the Treasury for Terrorism and Financial Intelligence

“[The United States is] working especially closely with our friends in the Gulf – who are stalwart partners in the anti-ISIL coalition – to ensure that they all have the tools in place to combat terrorist financing and that they all use those tools effectively.  We appreciate the close collaboration and strong steps taken by the Emiratis… to combat ISIL financing.”

 

Stuart Levey, Former US Treasury Undersecretary for Terrorism and Financial Intelligence

“There is a very strong alliance on all issues between the US and the UAE and the issue of Iran as well.  They also take seriously their commitments as a country that has articulated its support for the Financial Action Task Force principles and they take very seriously the future of their financial system and the reputation of their financial system.”

 

The Washington Institute for Near East Policy, November 2008

“The UAE has been particularly willing to take on difficult challenges in this area [terrorist financing].  … The UAE was forward-leaning in its attempts to tackle these issues. … More recently, the UAE also launched an initiative to try to regulate the many brokers located there. … The UAE has taken some other important steps recently to more closely regulate its business sector. In August 2007, the UAE passed a law allowing it to restrict exports for national security reasons. Soon after, the Emiratis detained a ship bound for Iran to determine whether chemicals on board violated either the UN resolutions or its recently passed export-control law.”

The Money Trail: Finding, Following, and Freezing Terrorist Finances

Richard Olson, Former US Ambassador to the UAE

“The UAE is committed to preventing the proliferation of weapons of mass destruction; it endorsed the Proliferation Security Initiative in early 2006. In August 2007 the UAE passed a comprehensive export control law empowering the federal authorities to take action against companies or shipments threatening UAE national security. The US has actively engaged Emirati authorities via the Export Control and Related Border Security program to provide training and discussed ongoing issues of bilateral concern via the bilateral Counter Proliferation Task Force.”

 

Stuart Levey, Former US Treasury Undersecretary for Terrorism and Financial Intelligence

“There is a very strong alliance on all issues between the US and the UAE and the issue of Iran as well.  They also take seriously their commitments as a country that has articulated its support for the Financial Action Task Force principles and they take very seriously the future of their financial system and the reputation of their financial system.”

Joint Hearing Before the House Committee on Foreign Affairs – April 2018

“Over the past few years, the UAE has taken a number of joint actions with the United States against exchange houses involved in illicit activity, including closing AI Zarooni Exchange, which the United States tied to a global money laundering organizations, and cutting off a Yemen-based exchange house that was providing financial services to AI Qaeda in the Arabian Peninsula (AQAP). "

Grading Counterterrorism Cooperation with the GCC States

Joint Hearing Before the House Committee on Foreign Affairs – April 2018

ADIA

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