Top Tips for Financial Crime Trends in the Middle East and Africa

Top Tips for Financial Crime Trends in the Middle East and Africa

April 29, 2021

Financial Crime Trends Across Middle East and Africa (MEA) – Summary

Businesses and criminals have had to adapt to the abrupt and far-reaching impacts of the COVID-19 pandemic. The pandemic also provided ample opportunities for criminals to devise new schemes and take advantage of a rapidly changing, uncertain environment.  Many financial institutions in MEA, particularly the Gulf Cooperation Council (GCC) struggled with slow performance, but most still plan to grow their compliance teams and increase compliance spend over the course of the year, with a focus on technology.  Regulators in MEA were already moving towards greater digitisation and use of technology to fight financial crime, and this trend has only been accelerated by the COVID-19 pandemic.

Below are some of the financial crime prevention enhancements across the GCC.


The UAE authorities have been extremely active in the first three months of 2021, issuing a series of new regulations and guidance, and handing out fines to several regulated entities. The Dubai Multi Commodities Centre (DMCC) Free Zone has entered a memorandum of understanding with the Securities and Commodities Authority (SCA) to establish a regulatory framework for businesses offering, issuing, listing, and trading crypto assets in DMCC. Crypto firms will be able to apply for bespoke license offered by the DMCC Crypto Centre.

The Cabinet has issued Resolution No. 16 of 2021 regarding non-financial businesses and professions (DNFBPs), and a list of 26 different offences and applicable fines relating to DNFBPs’ AML/CTF obligations. Relevant entities include real estate agents, gold dealers, auditors, and corporate service providers, all of which must register with the relevant authorities by 31 March 2021 to avoid penalties. The Cabinet has also approved the establishment of an Executive Office of Anti-Money Laundering and Countering the Financing of Terrorism. This office will oversee the implementation of the UAE’s National AML/CFT Strategy and National Action Plan.


The Bank of Israel has issued a publication detailing the measures taken and barriers removed to enable the establishment of digital banks. It says that to encourage the establishment of new banks, it has decided to standardise, shorten, and simplify the process, remove entry barriers to the banking system, and create regulatory certainty at an early stage of the process for any entrepreneur interested in establishing a bank.


The Central Bank of Bahrain (CBB) has announced the launch of an eKYC platform as part of the country’s digital transformation strategy. The platform, the first of its kind in the region, is intended for retail banks, financial services providers, and money exchange networks and is operated by BENEFIT in collaboration with the Information and eGovernment Authority (IGA) under the supervision of the CBB.

Emerging Financial Crime Trends across MEA

  1. Fraud and Covid 19 – COVID-19 have created opportunities for organised criminals and fraudsters across the globe, and MEA is no exception. The UAE, for instance, saw a 250% increase last year in cyberattacks, including phishing and ransomware incidents.
  2. Cryptocurrency – The growth of cryptocurrency remained relatively low-scale but continued to show promise across MEA. Crypto is perceived to be a high-risk sector but this does not mean it should be off-limits. With greater knowledge and training on the associated risks and necessary controls, those risks can be mitigated.
  3. Transparency and accessibility of data – A small number of governments have made moves to align themselves with international standards, such as the UAE, Egypt, and Kenya, all of whom introduced new requirements in 2020 for companies to declare their ultimate beneficial owners. However, there is still a long way to go.
  4. Corporate Fraud – From fake degrees and doctored CVs to false insurance claims and bogus bills, corporate fraud in MEA is on the rise. An investment in document verification tool such as Print Data Secure will minimise risk in this area.
  5. Bribery and Corruption – the lack of counter-corruption model legislation such as UK Bribery Act 2010 often means that policing the business areas such as the Dubai International Finance Centre (DIFC) falls to private companies as the regulator does not have the resources to cover the scale of the problem.
  6. Investor scams on the rise – the rise across the UAE is because the country is ripe for development and fraudsters have found it easy to prey on foreign victims who are drawn to opportunities but are unwilling to carry out proper due diligence.
  7. Nascent Regulatory Regime – the issues relating to fraud and corruption are of concern because there is no standardised. legislation across the region. For example, the definition of fraud and fraudulent activities are different across MEA.

Top Tips for Financial Crime Trends in MEA

  1. Understanding emerging risks is the single most important tip in preventing financial crime. An overreliance on process and technology without proper investment in understanding risks and people managing those risks is the root cause of most problems.
  2. Applying an effective risk-based approach will help prioritise and solve most problems; not create new ones.
  3. Stamping out “box ticking” compliance, applying bespoke compliance solutions in line with risk appetite and considering culture and operating environment is critical in mitigating risk.
  4. Artificial intelligence and machine learning tools, if properly tuned and aligned to the business will help with mitigating risks.
  5. Hands on training and competence of people managing financial crime risks is the lifeline of the business. Without this it impossible to win the battle against financial crime.

Where does Kharis & Knoble come in?

A robust, consistent, and sustainable compliance systems and controls must be in place to ensure compliance on an ongoing basis as well as adapting to any changes in regulatory requirements. At Kharis & Knoble, we provide top tier risk and compliance solutions which will help you navigate the regulatory landscape in your industry.

We will do a root and branch review and help you understand your unique set of risks. We will provide an in-depth analysis of your risks, based on your clients, products and services, geographical location, and delivery channel. We will equip you with bespoke solutions, tailor-made to suite your needs. We will provide hands on, on the shop floor training for your people and equip them to solve real life problems rather than hypothetical scenarios.

By using Kharis & Knoble, you will understand your risks and never have to worry about regulatory changes again.


Bisi Giwa – CEO

Legal, Risk and Compliance Expert for over 20 years. Specialises in

Financial Crime and Regulatory Compliance.

John Webb – Consultant

Chief Audit Executive for over 30 years. Specialises in Fraud and Internal Audit.

Tony Cuff – Consultant

Trade Finance Expert for over 40 years. Specialises in Trade Finance, Capital Markets, secondary Market Trading and Payments.


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