CMA Circular No. 6/2021 of 2021 · UAE Federal
SCA notice of 22 November 2021 updating the list of high-risk jurisdictions subject to a call for action and jurisdictions under increased monitoring, and the counter-measures to apply.
Notice No. 6 of 2021 passes to CMA-licensed entities (then SCA-licensed) and licensed exchanges the National AML/CFT Committee's decision to adopt the FATF "call for action" list (the black list) and the "increased monitoring" list (the grey list), with mandatory enhanced due diligence and counter-measures for black-list jurisdictions and risk-based measures for grey-list ones.
The notice is dated 22 November 2021 (reference 6-2021) and updates the Authority's Notice No. 1 of 2021 of 24 March 2021. It rests on Article 12(3) of Federal Decree-Law No. 20 of 2018, which gave the National Anti-Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations Committee the task of identifying high-risk countries and the counter-measures to apply, and on Article 22 of Cabinet Decision No. 10 of 2019, which required enhanced due diligence and the Committee's counter-measures for high-risk jurisdictions.
The Committee decided to adopt the FATF black list with the counter-measures in the interpretive note to Recommendation 19, and the grey list with risk-proportionate procedures that may include enhanced due diligence. Financial institutions, DNFBPs, virtual asset service providers and non-profit organisations must review the FATF and Committee lists regularly, reflect them in their controls, and re-evaluate measures for countries removed from the lists. For black-list jurisdictions they must apply enhanced due diligence to all relationships and transactions, file suspicious transaction reports using the goAML High Risk Jurisdiction templates, and may not rely on third parties located there for due diligence.
The notice itself names no countries; the lists move with each FATF statement. Its legal basis has since been replaced: Federal Decree-Law No. 10 of 2025 (in force 14 October 2025) and Cabinet Resolution No. 134 of 2025 (in force 14 December 2025) now carry the AML/CFT duties.
All entities licensed by the Securities and Commodities Authority (now the Capital Market Authority) and licensed exchanges; the Committee decision it relays also addresses financial institutions, DNFBPs, virtual asset service providers and non-profit organisations in the UAE.
English official text in 5 passages. Open the full text or jump to a provision:
| Paragraph 1 | Records that the National AML/CFT Committee has updated the high-risk and increased-monitoring jurisdiction lists and the counter-measures, and that the notice updates the Authority's Notice No. 1 of 2021 of 24 March 2021. |
| Paragraph 2 | Cites Article 12(3) of Federal Decree-Law No. 20 of 2018 on the Committee's power to identify high-risk countries and counter-measures, and Article 22 of Cabinet Decision No. 10 of 2019 on enhanced due diligence. |
| Item 1 | The Committee adopts the FATF list of high-risk jurisdictions subject to a call for action (black list) and the counter-measures in the interpretive note to FATF Recommendation 19. |
| Item 2 | The Committee adopts the list of jurisdictions under increased monitoring (grey list), with risk-proportionate procedures that may include enhanced due diligence under the interpretive note to Recommendation 10. |
| Item 3 | All financial institutions, DNFBPs, VASPs and non-profit organisations must review the FATF and Committee lists regularly, reflect them in their measures, and re-evaluate measures for countries removed from the lists. |
| Paragraph 3 | For black-list jurisdictions: enhanced due diligence on all relationships and transactions, STRs through the goAML High Risk Jurisdiction templates, and no reliance on third parties located there for due diligence. |
| Paragraph 4 | Financial institutions and VASPs must also implement targeted financial sanctions under the UN Security Council resolutions and Cabinet Decision No. 74 of 2020. |
Polaris is not licensed by the CMA. The notice matters to our work because country risk drives onboarding decisions for the companies we form and administer. When a client planning a CMA-licensed activity has shareholders, UBOs or counterparties connected to black- or grey-list jurisdictions, we flag the enhanced due diligence and reliance restrictions early, so the licensing route, the bank account and the ownership structure are planned around them. We apply the same list review to our own corporate service clients and keep the supporting KYC and UBO evidence in the client file.
| Cites | Targeted Financial Sanctions Regulation · 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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