Our summary
This guidance from the Central Bank of the UAE, dated 26 November 2025, explains how licensed financial institutions should manage the risk of trade-based money laundering and illicit transshipment. It does not create new legal duties. Instead, it explains what the CBUAE expects firms to do to meet their existing duties under Federal Decree-Law No. 10 of 2025 and related rules. It applies to banks, exchange houses, finance and investment companies, payment service providers, virtual asset service providers, registered hawala providers and insurance firms supervised by the CBUAE. Firms are expected to show compliance within one month of the guidance taking effect.
The document describes common schemes, such as over- and under-invoicing, multiple invoicing, false descriptions of goods, shell companies, free zones and fake documents. It also explains illicit transshipment, where goods pass through a third country to avoid sanctions, embargoes or export controls, a known risk for a trade hub like the UAE. It names higher-risk goods (such as gold, vehicles and parts, electronics and textiles), covers dual-use goods and trade finance products, and sets out expected controls: enterprise-wide risk assessment, enhanced due diligence, sanctions screening, transaction monitoring, reporting, training, independent audit and five-year record keeping. An annex lists red flags for transactions, jurisdictions, goods and company structures.
How auditors use it: Use the red flag annex as a test checklist for trade finance and correspondent payments. Check that the enterprise-wide risk assessment covers TBML and transshipment, that staff can identify dual-use goods, and that monitoring rules reflect the typologies in the guidance.