Papers by Dina ElYacoubi
Journal of Money Laundering Control, Mar 30, 2020
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Journal of Money Laundering Control, 2020
Purpose The purpose of this paper is to unpack the customer due diligence (CDD) vulnerabilities a... more Purpose The purpose of this paper is to unpack the customer due diligence (CDD) vulnerabilities and to examine and analyze the UAE specific dynamics that make the country exposed to these threats. This research also intends to put on the table suitable solutions and remedial action steps that the UAE government, regulators and financial institutions (FIs) can adopt. Design/methodology/approach This study is qualitative in nature. Findings Despite the impressive regulatory framework and the satisfactory practices by FIs, there still remains some UAE specific challenges that make it difficult to undertake CDD for certain customers. The challenges that were identified include difficulties in Arabic names, complications in identifying the beneficial owners, impediments in establishing the source of wealth/funds, concerns with politically exposed persons, the increasing cost of compliance that resulted in a pattern of de-risking within FIs. Research limitations/implications The internati...
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EMERALD PUBLISHING LIMITED - The Journal of Money Laundering Control - JMLC, 2020
Purpose:
The purpose of this paper is to unpack the customer due diligence (CDD) vulnerabilities ... more Purpose:
The purpose of this paper is to unpack the customer due diligence (CDD) vulnerabilities and to examine and analyze the UAE specific dynamics that make the country exposed to these threats. This research also intends to put on the table suitable solutions and remedial action steps that the UAE government, regulators and financial institutions (FIs) can adopt.
Design/methodology/approach
This study is qualitative in nature.
Findings:
Despite the impressive regulatory framework and the satisfactory practices by FIs, there still remains some UAE specific challenges that make it difficult to undertake CDD for certain customers. The challenges that were identified include difficulties in Arabic names, complications in identifying the beneficial owners, impediments in establishing the source of wealth/funds, concerns with politically exposed persons, the increasing cost of compliance that resulted in a pattern of de-risking within FIs.
Research limitations/implications:
The international bodies whose mandate is to formulate the necessary anti-money laundering and combating the financing of terrorism policies and regulations for global implementation together with Association of Certified Anti-Money Laundering Specialists (ACAMS) have published sufficient studies on CDD-related issues in the UAE. Yet on the other hand, very limited literature was found by independent scholars. This paper will, therefore, largely reference publications by Financial Action Task Force, the International Narcotics Control Strategy Report and ACAMS. It will also include works by respected law firms that have operations in the UAE, local publications, government documents, academic papers by the International Monetary Fund and the World Bank, legal journals and others.
Originality/value:
Illicit actors exploit the UAE’s relatively open business environment, a multitude of global banks and exchange houses and global transportation links to undertake illicit financial activity […] the UAE does not have any major anti-money laundering (AML) deficiencies. However, the monitoring of FIs for AML purposes, particularly in the area of CDD, could be improved. This paper unpacks the CDD vulnerabilities and analyzes the UAE specific dynamics that make the country exposed to these threats. This research also puts on the table suitable remedial action steps that the UAE government, regulators and FIs can adopt.
Keywords:
AML/CFT Framework
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Bookmarks Related papers MentionsView impact
Thesis Chapters by Dina ElYacoubi
The UAE enjoys political stability, liberal business environment and robust economic development.... more The UAE enjoys political stability, liberal business environment and robust economic development. It has a very thriving real estate market and it houses a world class financial services hub that sits in Dubai known as the Dubai International Financial Center - DIFC. The UAE is also a hub for trading gold, diamonds, precious metals, arts and much more. With this significant business and economic status that the UAE has acquired that makes it a vital center for trade, financial activity and transportation, it naturally attracts monies from all around the world and as a result, this leaves the country vulnerable to criminal financial activities. There is also the particular geographic location and the implications of business linkages with high risk and less stable neighboring countries that the UAE has an open and free trade market with. No wonder, the UAE has very peculiar and particular dynamics and consequently, the UAE is also vulnerable to trade based money laundering activities - TBML through trading companies that have activities with sanctioned countries or through commodities used as counter valuation in hawala transactions. Evidently, there is a strong correlation between the dynamics mentioned above to the fact that the UAE appeals to criminals that are keen to use its financial system for financial crime activities.
The Financial Action Task Force - FATF and other international bodies that are dedicated to protecting the global financial system from ML and TF activities place Customer Due Diligence - CDD at the heart of an effective AML/CFT framework. As such, the most important focus needs to be put on CDD measures and practices which are the primary and most critical part of any compliance program which is intended to ensure that financial institutions - FIs know the person on whose behalf they are holding funds for or conducting transactions for and to identify any potential risk that he/she may pose. An effective CDD undertaking requires identifying and verifying the customer and the beneficial owner(s), understanding and collecting the required information on the purpose and the intended nature of the business relationship, validating the source of wealth as well as maintaining an ongoing monitoring of the business relationship.
The UAE invested significantly in improving its regulatory structure and made immense progress by putting the appropriate legal framework. Suitably, complying with regulatory requirements is a key focus for FIs in the UAE. And yet, despite the good legislative system that is now available and the satisfactory practices by FIs, there still remains some UAE specific challenges that make it, at times, more difficult to undertake CDD for certain customers. Challenges include complications in identifying the beneficial owners, impediments in establishing the source of wealth, concerns with politically exposed persons - PEPs, derisking and others.
This study is qualitative in nature. The purpose of this paper is to unpack the CDD vulnerabilities and to examine and analyze the UAE specific dynamics that make the country exposed to these threats. This research also intends to put on the table suitable solutions and remedial action steps that the UAE government, regulators and FIs can adopt.
The international bodies whose mandate is to formulate the necessary AML/CFT policies and regulations for global implementation together with ACAMS have published sufficient studies on CDD related issues in the UAE. Yet on the other hand, very limited literature was found by independent scholars. This paper will therefore largely reference publications by FATF, the INCSR and ACAMS. It will also include works by respected law firms that have operations in the UAE, local publications, government documents, academic papers by the IMF and the World Bank, legal journals and others. This research will also delve into other publications that are not necessarily UAE specific but which will rather provide insightful thoughts, considerations and add further in-depth understanding of CDD related problems that the UAE can relate to and yield possible solutions for the local regulators and FIs to consider. Publications include academic papers by esteemed scholars, legal journals, industry specific magazines and others.
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Conference Presentations by Dina ElYacoubi
PREPARED AND PRESENTED TO THE LITERATURE FRENCH GROUP IN AMMAN JORDAN
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Papers by Dina ElYacoubi
The purpose of this paper is to unpack the customer due diligence (CDD) vulnerabilities and to examine and analyze the UAE specific dynamics that make the country exposed to these threats. This research also intends to put on the table suitable solutions and remedial action steps that the UAE government, regulators and financial institutions (FIs) can adopt.
Design/methodology/approach
This study is qualitative in nature.
Findings:
Despite the impressive regulatory framework and the satisfactory practices by FIs, there still remains some UAE specific challenges that make it difficult to undertake CDD for certain customers. The challenges that were identified include difficulties in Arabic names, complications in identifying the beneficial owners, impediments in establishing the source of wealth/funds, concerns with politically exposed persons, the increasing cost of compliance that resulted in a pattern of de-risking within FIs.
Research limitations/implications:
The international bodies whose mandate is to formulate the necessary anti-money laundering and combating the financing of terrorism policies and regulations for global implementation together with Association of Certified Anti-Money Laundering Specialists (ACAMS) have published sufficient studies on CDD-related issues in the UAE. Yet on the other hand, very limited literature was found by independent scholars. This paper will, therefore, largely reference publications by Financial Action Task Force, the International Narcotics Control Strategy Report and ACAMS. It will also include works by respected law firms that have operations in the UAE, local publications, government documents, academic papers by the International Monetary Fund and the World Bank, legal journals and others.
Originality/value:
Illicit actors exploit the UAE’s relatively open business environment, a multitude of global banks and exchange houses and global transportation links to undertake illicit financial activity […] the UAE does not have any major anti-money laundering (AML) deficiencies. However, the monitoring of FIs for AML purposes, particularly in the area of CDD, could be improved. This paper unpacks the CDD vulnerabilities and analyzes the UAE specific dynamics that make the country exposed to these threats. This research also puts on the table suitable remedial action steps that the UAE government, regulators and FIs can adopt.
Keywords:
AML/CFT Framework
Thesis Chapters by Dina ElYacoubi
The Financial Action Task Force - FATF and other international bodies that are dedicated to protecting the global financial system from ML and TF activities place Customer Due Diligence - CDD at the heart of an effective AML/CFT framework. As such, the most important focus needs to be put on CDD measures and practices which are the primary and most critical part of any compliance program which is intended to ensure that financial institutions - FIs know the person on whose behalf they are holding funds for or conducting transactions for and to identify any potential risk that he/she may pose. An effective CDD undertaking requires identifying and verifying the customer and the beneficial owner(s), understanding and collecting the required information on the purpose and the intended nature of the business relationship, validating the source of wealth as well as maintaining an ongoing monitoring of the business relationship.
The UAE invested significantly in improving its regulatory structure and made immense progress by putting the appropriate legal framework. Suitably, complying with regulatory requirements is a key focus for FIs in the UAE. And yet, despite the good legislative system that is now available and the satisfactory practices by FIs, there still remains some UAE specific challenges that make it, at times, more difficult to undertake CDD for certain customers. Challenges include complications in identifying the beneficial owners, impediments in establishing the source of wealth, concerns with politically exposed persons - PEPs, derisking and others.
This study is qualitative in nature. The purpose of this paper is to unpack the CDD vulnerabilities and to examine and analyze the UAE specific dynamics that make the country exposed to these threats. This research also intends to put on the table suitable solutions and remedial action steps that the UAE government, regulators and FIs can adopt.
The international bodies whose mandate is to formulate the necessary AML/CFT policies and regulations for global implementation together with ACAMS have published sufficient studies on CDD related issues in the UAE. Yet on the other hand, very limited literature was found by independent scholars. This paper will therefore largely reference publications by FATF, the INCSR and ACAMS. It will also include works by respected law firms that have operations in the UAE, local publications, government documents, academic papers by the IMF and the World Bank, legal journals and others. This research will also delve into other publications that are not necessarily UAE specific but which will rather provide insightful thoughts, considerations and add further in-depth understanding of CDD related problems that the UAE can relate to and yield possible solutions for the local regulators and FIs to consider. Publications include academic papers by esteemed scholars, legal journals, industry specific magazines and others.
Conference Presentations by Dina ElYacoubi
The purpose of this paper is to unpack the customer due diligence (CDD) vulnerabilities and to examine and analyze the UAE specific dynamics that make the country exposed to these threats. This research also intends to put on the table suitable solutions and remedial action steps that the UAE government, regulators and financial institutions (FIs) can adopt.
Design/methodology/approach
This study is qualitative in nature.
Findings:
Despite the impressive regulatory framework and the satisfactory practices by FIs, there still remains some UAE specific challenges that make it difficult to undertake CDD for certain customers. The challenges that were identified include difficulties in Arabic names, complications in identifying the beneficial owners, impediments in establishing the source of wealth/funds, concerns with politically exposed persons, the increasing cost of compliance that resulted in a pattern of de-risking within FIs.
Research limitations/implications:
The international bodies whose mandate is to formulate the necessary anti-money laundering and combating the financing of terrorism policies and regulations for global implementation together with Association of Certified Anti-Money Laundering Specialists (ACAMS) have published sufficient studies on CDD-related issues in the UAE. Yet on the other hand, very limited literature was found by independent scholars. This paper will, therefore, largely reference publications by Financial Action Task Force, the International Narcotics Control Strategy Report and ACAMS. It will also include works by respected law firms that have operations in the UAE, local publications, government documents, academic papers by the International Monetary Fund and the World Bank, legal journals and others.
Originality/value:
Illicit actors exploit the UAE’s relatively open business environment, a multitude of global banks and exchange houses and global transportation links to undertake illicit financial activity […] the UAE does not have any major anti-money laundering (AML) deficiencies. However, the monitoring of FIs for AML purposes, particularly in the area of CDD, could be improved. This paper unpacks the CDD vulnerabilities and analyzes the UAE specific dynamics that make the country exposed to these threats. This research also puts on the table suitable remedial action steps that the UAE government, regulators and FIs can adopt.
Keywords:
AML/CFT Framework
The Financial Action Task Force - FATF and other international bodies that are dedicated to protecting the global financial system from ML and TF activities place Customer Due Diligence - CDD at the heart of an effective AML/CFT framework. As such, the most important focus needs to be put on CDD measures and practices which are the primary and most critical part of any compliance program which is intended to ensure that financial institutions - FIs know the person on whose behalf they are holding funds for or conducting transactions for and to identify any potential risk that he/she may pose. An effective CDD undertaking requires identifying and verifying the customer and the beneficial owner(s), understanding and collecting the required information on the purpose and the intended nature of the business relationship, validating the source of wealth as well as maintaining an ongoing monitoring of the business relationship.
The UAE invested significantly in improving its regulatory structure and made immense progress by putting the appropriate legal framework. Suitably, complying with regulatory requirements is a key focus for FIs in the UAE. And yet, despite the good legislative system that is now available and the satisfactory practices by FIs, there still remains some UAE specific challenges that make it, at times, more difficult to undertake CDD for certain customers. Challenges include complications in identifying the beneficial owners, impediments in establishing the source of wealth, concerns with politically exposed persons - PEPs, derisking and others.
This study is qualitative in nature. The purpose of this paper is to unpack the CDD vulnerabilities and to examine and analyze the UAE specific dynamics that make the country exposed to these threats. This research also intends to put on the table suitable solutions and remedial action steps that the UAE government, regulators and FIs can adopt.
The international bodies whose mandate is to formulate the necessary AML/CFT policies and regulations for global implementation together with ACAMS have published sufficient studies on CDD related issues in the UAE. Yet on the other hand, very limited literature was found by independent scholars. This paper will therefore largely reference publications by FATF, the INCSR and ACAMS. It will also include works by respected law firms that have operations in the UAE, local publications, government documents, academic papers by the IMF and the World Bank, legal journals and others. This research will also delve into other publications that are not necessarily UAE specific but which will rather provide insightful thoughts, considerations and add further in-depth understanding of CDD related problems that the UAE can relate to and yield possible solutions for the local regulators and FIs to consider. Publications include academic papers by esteemed scholars, legal journals, industry specific magazines and others.