Dissertation Anti Money Laundering

Accordingly, the UAE remains perceived as a largely non-­‐transparent jurisdiction when it comes to financial crimes.Recent (2016) legislative developments underscore the UAE’s effort to change this, as it is due for a new FATF evaluation in 2019.Credit institutions are said to be on the frontline of this battle and therefore, much of the responsibility of preventing and detecting such crimes falls upon them.

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Where necessary, suggestions were put forward for consideration.

The role of credit institutions in the fight against money laundering and terrorist funding is also analysed.

Beyond isolated interferences of information systems to AML, their interrelations are further examined in order to reflect on the emergent complexity that often distorts cause-and-effect AML manipulations.

The theoretical contributions put forward, constitute a systems theoretical application and an expansion of technological/systemic interferences, while the practical contributions to AML cover broader systems-theoretical reflections on the domain, technological integration within financial institutions for targeting ML, feedback relations between financial institutions and Financial Intelligence Units, as well as the systemic consequences for the newly implemented risk-based approach.

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This thesis provides an in-depth analysis of the international and local initiatives undertaken in combatting money laundering and terrorist financing.

Reference is particularly made to the Financial Action Task Force’s (‘FATFs’) 40 9 Recommendations and other guidelines, the EU’s Directives on preventing money laundering and funding of terrorism, the Prevention of Money Laundering and Funding of Terrorism Regulations and the Financial Intelligence Analysis Unit’s (‘FIAUs’) Implementing Procedures.

This theoretical approach of ST is appropriated in order to describe the domain of Anti-Money Laundering (AML) as a system in itself and at the same time examine the consequences that technology comes to play within the system of AML.

While the contemporary phenomenon of AML has been reduced mostly into a set of technological consequences from profiling technologies (technologies that attempt within financial institutions to model and simulate money-laundering behaviour for the generation of suspicious transactions), this dissertation takes a different approach.