Central Bank of the UAE Guidance for Licensed Financial Institutions on Risks Related to Trade-Based Money Laundering (“TBML”) and Transshipment

October, 2025.

Contents

4.3. Targeted Financial Sanctions Obligations ...40 4.3.1. Confirmed Matches ...43 4.3.2. Partial Name Matches ...43 4.4. Transaction Monitoring and Suspicious Transaction/Activity Reporting ...44 4.4.1. Transaction Monitoring ...44 4.4.2. Suspicious Transaction/Activity Reporting ...45 4.5. Governance and Independent Audit ...47 4.6. Training ...47 4.7. Record-keeping ...48 Annex 1. TBML and Illicit Transshipment Red Flags ...49 Annex 2. Visual Synopsis ...54 Annex 3. Synopsis of the Guidance ...55

1. Introduction

As a major financial centre, trade is central to the United Arab Emirates (“UAE”)’s economy. Situated at the crossroads of significant trade routes, the UAE’s ports make the country an essential distribution hub in global supply chains and the international movement of goods. In addition, the UAE’s commitment to business and commerce, as evidenced through the expansion of the country’s Financial Free Zone...