Cross-border transactions have become a core part of business operations in the UAE’s globally connected economy. However, as international money flows increase, so do the risks of money laundering, tax evasion, illicit fund movements, and terrorism financing. This makes AML compliance for cross-border dealings one of the most critical responsibilities for UAE businesses in 2025.

Accounting firms such as Swenta now play a major role in helping companies navigate these risks—ensuring accurate documentation, real-time monitoring, and compliance with both UAE and international standards.

Why Cross-Border Transactions Are High-Risk

Cross-border transactions often involve multiple jurisdictions, banks, regulations, and financial intermediaries. For criminals, this complexity is ideal because it allows them to disguise the origin or ownership of illicit funds.

Some of the biggest risks include:

1. Complex fund movements across multiple countries

This makes it difficult to determine where the money originated and where it will eventually land—a common layering tactic.

2. Use of offshore accounts and tax haven structures

Entities based in secrecy jurisdictions can be used to hide beneficial ownership.

3. Variations in AML regulations between countries

A weak regulatory environment in one jurisdiction can expose UAE businesses to global reputational and financial risks.

4. Difficulty verifying foreign clients and partners

When onboarding international clients, verifying documents or background information becomes challenging.

This is why UAE authorities have tightened supervision over cross-border money flows as part of the country’s post-FATF delisting commitments.

Why Real Estate Is Often Targeted in Cross-Border Laundering

Criminals often rely on cross-border fund transfers to purchase property in stable economies. Real estate presents several attractive features:

• High-value transactions, enabling quick movement of large funds

• Lower historic oversight compared to financial institutions

• Ability to hide ownership behind shell companies

• Conversion of illegal money into long-term assets

In some countries, international laundering through real estate has inflated property prices, harmed communities, and destabilised local economies. The UAE has acknowledged these vulnerabilities and strengthened supervision accordingly.

Understanding the Risk-Based Approach (RBA) for Cross-Border AML

A Risk-Based Approach requires businesses to adjust AML efforts based on the level of risk associated with each client, region, product, or transaction type.

Under FATF guidance and UAE law, companies must:

• Identify risks associated with the client’s country

• Evaluate foreign transaction patterns

• Conduct enhanced due diligence (EDD) for high-risk jurisdictions

• Maintain updated verification for all international counterparties

• Apply stricter controls where inconsistencies arise

AML consultants in Dubai—and accounting firms like Swenta—help businesses properly implement RBA for international transactions.

Key AML Steps for Cross-Border Transactions

To stay compliant, UAE businesses must strengthen several AML measures:

1. Strong KYC & Beneficial Ownership Verification

Foreign clients require deeper verification, including:

• Passport validation

• Business registration checks

• International sanctions list screening

• Identifying ultimate beneficial owners (UBOs)

This ensures no hidden parties are involved in the transaction.

2. Understanding the Purpose of the International Deal

Businesses must assess:

• Why the transaction is happening

• Why the specific country is involved

• Whether the pricing or structure is unusual

Unexplained urgency or complex payment routes are red flags.

3. Following the Money – Source of Funds (SOF) & Source of Wealth (SOW)

Cross-border transactions often involve:

• Offshore companies

• Cryptocurrency exchanges

• Multilayered holding companies

• High-risk banks

UAE businesses must trace the legitimacy of funds before accepting them.

4. Continuous Monitoring of International Clients

Monitoring cannot stop after onboarding. Ongoing review helps detect:

• Changes in transaction behaviour

• Sudden large transfers

• Suspicious offshore involvement

• Connections to high-risk countries

This aligns with 2025 AMLD expectations across DNFBPs.

Supervisory Expectations: UAE’s Focus on International Transactions

The UAE’s AMLD (Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department) intensifies oversight over sectors engaged in cross-border activity such as:

• Corporate service providers

• Real estate brokers

• Jewellery traders

• Legal firms

• Accounting firms

These businesses must ensure their internal control systems match global AML expectations, especially in sectors still growing or lacking mature compliance frameworks.

Weak or Emerging Markets: Why They Require Enhanced Due Diligence

The FATF and UAE authorities have highlighted that certain jurisdictions pose higher risks, especially those with:

• Weak AML enforcement

• Limited regulatory supervision

• High corruption levels

• Opaque ownership structures

• No beneficial ownership registry

For clients linked to such regions, enhanced due diligence is mandatory.

Practical Compliance Steps for Cross-Border AML Risk Management

To help businesses navigate global AML risks, experts recommend:

• Standardized due diligence checklists

• Technology-driven screening tools

• Training employees on country-specific risks

• Setting stricter internal approval workflows

• Real-time monitoring of transaction patterns

• Professional guidance from AML advisors in UAE

These steps create a strong compliance framework for international dealings.

Swenta assists companies by:

• Designing cross-border AML compliance frameworks

• Screening foreign clients and partners

• Reviewing SOF/SOW documentation

• Supporting goAML reporting for suspicious international activity

• Performing AML audits

• Training teams on country risk indicators

• Implementing automated solutions for risk scoring and monitoring

Businesses gain confidence and protection against regulatory penalties.

In 2025, UAE companies engaging in international operations must strengthen their AML systems more than ever. Global fund movements, offshore structures, and multi-jurisdictional payments bring new vulnerabilities that require proactive detection and management.

With expert support from accounting and compliance specialists like Swenta, UAE businesses can stay ahead of regulatory expectations and protect themselves from financial, operational, and reputational risks.