Press Release / / 07.03.19

FATF Assessment Team Must Focus on Issues Connecting UAE to Conflict in East and Central Africa

Washington, DC – The United Arab Emirates (UAE)’s Financial Action Task Force’s (FATF) onsite mutual evaluation begins this week. The FATF mutual evaluation process is a crucial step for countries attempting to improve their domestic anti-money laundering and countering the financing of terrorism (AML/CFT) framework and to demonstrate the efficacy of the systems they have developed.

Given the FATF’s stated focus on efficacy, The Sentry urges the joint FATF-MENAFATF assessment team to take note of the money laundering vulnerabilities and challenges in enforcement that allow illicit actors connected to conflict and mass atrocities in East and Central Africa to exploit the Emirati financial system for personal gain. The Sentry also encourages the UAE government to strengthen the implementation of its AML/CFT laws to prevent abuse by kleptocrats and their financial facilitators.

Hilary Mossberg, Senior Advisor to The Sentry, said: “Kleptocrats use the same money laundering techniques as terrorist networks and organized crime. If kleptocrats are abusing the Emirati financial system, other illicit groups may be doing the same. This mutual evaluation report should provide the Emirati officials with a blueprint of how to improve their domestic anti-money laundering controls and prevent nefarious actors from taking advantage of the holes in the current system.”

The UAE continues to be an important destination for violent kleptocrats, their families, and business associates to launder the proceeds of illicit activities in countries such as the Democratic Republic of Congo (Congo), South Sudan, and Sudan and to access the international financial system and supply chain.  As documented last year by The Sentry, the UAE serves as a key transit point for conflict gold from Congo. According to the UN Group of Experts on Congo and corroborated by The Sentry’s own investigations, the conflict gold trade from Congo is worth an estimated $300 to $600 million per year. Gold is the main funder of armed groups and criminal elements in eastern Congo, where an estimated three to seven million people have died as a result of armed conflict.

The UAE is also a jurisdiction where Politically Exposed Persons (PEPs) from South Sudan and Congo have reportedly used companies to purchase homes abroad with the proceeds of grand corruption and profit off of state contracts awarded to companies owned by the relatives of former heads of state. The Sentry’s investigations have also found that there are PEP-owned South Sudanese banks with possible nested correspondent banking relationships in the UAE.  These nested accounts through East African correspondent banks provide South Sudanese financial institutions with access to the global financial market, but PEPs leverage this access to send ill-gotten gains abroad.

The Sentry looks forward to the FATF’s mutual evaluation of the UAE, which should provide Emirati authorities with a clear roadmap for how to strengthen their country’s AML/CFT system.  The Sentry calls on the UAE to prioritize the effective implementation of its existing AML laws and regulations, and more closely scrutinize its gold and banking sectors to root out misuse by kleptocrats and their financial facilitators.

For media inquiries or interview requests, please contact: Greg Hittelman, Director of Communications, +1 310 717 0606, [email protected].


The Sentry is an investigative and policy team that follows the dirty money connected to African war criminals and transnational war profiteers and seeks to shut those benefiting from violence out of the international financial system. By disrupting the cost-benefit calculations of those who hijack governments for self-enrichment in East and Central Africa, the deadliest war zone globally since World War II, we seek to counter the main drivers of conflict and create new leverage for peace, human rights, and good governance. Co-founded by George Clooney and John Prendergast, The Sentry is composed of financial investigators, international human rights lawyers, and regional experts, as well as former law enforcement agents, intelligence officers, policymakers, investigative journalists, and banking professionals.

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