Country Reports on Terrorism 2012

effect. In 2012, five retired ICE and CBP personnel were under direct contract of the UAE
Ministry of Interior while six were under direct contract of the ADCA. All served the respective
academies as subject-matter experts, course developers, and instructors. The two academies
trained approximately 700 immigration and customs personnel in 2012.
A critical factor that poses a challenge to the effectiveness of the UAE’s law enforcement, border
security, and judicial system is the country’s lack of human capacity. Emiratis compose only 11
percent of the country’s total population, making it structurally difficult to develop the country’s
human resources to counter the full range of terrorist activities. Despite this, the UAE
government remains vigilant in its overall counterterrorism pursuits.
Countering Terrorist Finance: The UAE is a member of the Middle East and North Africa
Financial Action Task Force, a Financial Action Task Force-style regional body, and chairs the
Training and Typologies Working Group. It is a major international banking and trading center.
Its Financial Intelligence Unit (FIU), the Anti-Money Laundering and Suspicious Cases Unit in
the UAE Central Bank, is a member of the Egmont Group. The UAE continued efforts to
strengthen its institutional capabilities to combat terrorist financing, but challenges remained
with its enforcement of local and international law. The UAE’s last mutual evaluation report in
2008 recommended it amend the federal anti-money laundering (AML) law and increase
dedicated resources available to the Central Bank's Financial Intelligence Unit.
The Central Bank continued to conduct AML training both locally and regionally, and was
expanding its cooperation with FIUs worldwide to bolster its ability to counter terrorist
finance. Exploitation of money transmitters by illicit actors, which included licensed exchange
houses, hawalas, and trading firms acting as money transmitters, remained a significant concern.
This vulnerability was compounded by the voluntary registration regime for hawalas and their
lack of enforceable Anti-Money Laundering/Combating the Financing of Terrorism of terrorism
obligations. Regional hawalas and associated trading companies in various expatriate
communities, most notably Somalis, have established clearinghouses, the vast majority of which
are not registered with the UAE government. There are some indications that trade-based money
laundering occurs in the UAE and that such activity might support terrorist groups in
Afghanistan, Pakistan, and Somalia. The UAE Central Bank provides direct oversight to the
Foreign Exchange and Remittance Group, the UAE’s exchange house industry group, but its
capacity and willingness to effectively monitor the sector remained unclear. Currently Emirati
authorities are not capable of supervising the vast number of hawalas in the country or enforcing
hawala compliance. Continuing from previous years, the United States and the UAE worked
together to strengthen efforts to counter terrorist finance, including cross-border Bulk Cash
Smuggling (BCS) and money laundering, with training, collaborative engagement with the local
financial community, and other bilateral government cooperation.
In September, the U.S. Federal Bureau of Investigation (FBI) Legal Attaché established a suboffice
at the U.S. Consulate in Dubai to assist with Counterterrorism/Terrorist Financing Matters
and provide a viable means to enhance cooperation between the FBI and UAE. Additionally, the
FBI provided training courses to Gulf Cooperation Council (GCC) law enforcement
counterparts.
146