CMA Circular No. 1/2021 of 2021 · UAE Federal
SCA notice to all licensed entities and exchanges updating the lists of high-risk jurisdictions and jurisdictions under increased monitoring and identifying the counter-measures financial institutions must apply.
Notice No. 1 of 2021, issued in English and Arabic by the Securities and Commodities Authority (now the Capital Market Authority) on 24 March 2021 to all its licensed entities and the licensed securities and commodities exchanges, passes on the decision of the UAE National Anti-Money Laundering and Combating Financing of Terrorism and Financing of Illegal Organisations Committee on how financial institutions must treat countries listed by the FATF.
Three general rules apply. The FATF list of high-risk jurisdictions subject to a call for action (the black list) is adopted, together with the enhanced due diligence measures in the relevant FATF public statement and the counter-measures in the interpretive note to Recommendation 19. The FATF list of jurisdictions under increased monitoring (the grey list) is adopted, with procedures that may include enhanced due diligence in line with the risk of dealings with persons from those jurisdictions. Every institution must check the lists regularly and each time the FATF updates them, and build them into its risk-based procedures.
For high-risk jurisdictions, enhanced due diligence applies to all business relationships and transactions, including with persons acting on their behalf, citing Article 4(2) of Cabinet Decision No. 10 of 2019 and paragraph 20 of the interpretive note to Recommendation 10. Institutions must apply the counter-measures they consider appropriate, and must report to the Financial Intelligence Unit any transaction involving a natural or legal person from a high-risk jurisdiction before carrying it out; the transaction may be executed only three working days after the report, and only if the FIU has not objected. Targeted financial sanctions under UN Security Council resolutions also apply.
Status: listed as in force. The lists it adopts move with each FATF update; the CMA's later Notice No. 6 of 2021 again updated them. Cabinet Decision No. 10 of 2019, which the notice cites, has been repealed and replaced by Cabinet Resolution No. 134 of 2025 under Federal Decree-Law No. 10 of 2025.
All entities licensed by the Securities and Commodities Authority (now the CMA) and the licensed securities and commodities exchanges in the UAE, as financial institutions for AML/CFT purposes, in their dealings with persons from FATF-listed jurisdictions.
English official text in 4 passages. Open the full text or jump to a provision:
| Paragraph 1 | Adopts the FATF black list of high-risk jurisdictions, with the enhanced due diligence in the FATF public statement and the counter-measures in the interpretive note to Recommendation 19. |
| Paragraph 2 | Adopts the FATF grey list of jurisdictions under increased monitoring, with procedures that may include enhanced due diligence proportionate to the risk of the dealings. |
| Paragraph 3 | Institutions must verify and review the lists regularly and every time the FATF updates them, and take them into account in counter-measures and risk-based procedures. |
| Section 'Jurisdictions Under Increased Monitoring' | Enhanced due diligence must be proportionate to the risks of relationships with persons from grey-list countries and adequate to reduce them, under Article 4(2) of Cabinet Decision No. 10 of 2019. |
| Section 'High-Risk Jurisdictions', item 1 | Enhanced due diligence applies to all business relationships and transactions with high-risk jurisdictions, including persons acting on their behalf. |
| Section 'High-Risk Jurisdictions', item 2 | Institutions must apply the counter-measures they consider appropriate to mitigate the risks described in the interpretive note to FATF Recommendation 19. |
| Section 'High-Risk Jurisdictions', item 3 | Any transaction involving a person from a high-risk jurisdiction must be reported to the FIU in advance and may be executed only after three working days without FIU objection. |
| Paragraph (closing) | Financial institutions must implement targeted financial sanctions under applicable UN Security Council resolutions. |
We are not licensed by the CMA. As a DNFBP ourselves we apply the equivalent high-risk country rules issued for our own sector, and for CMA-licensed clients we build the FATF list checks into the onboarding files and compliance manuals we maintain for them. The point clients most often miss is the prior FIU report and the three-working-day wait for any transaction with a person from a black-list jurisdiction; we flag it at onboarding so their compliance officer files it through goAML before anything is executed.
| Cites | AML Implementing Regulation 2019 (repealed) · AML Law 2018 (repealed) |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
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