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The Abuse of Non-Profit Organizations - Guidance for Reporting Entities

02/09/2021
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Non-profit Organizations (NPOs) are key stakeholders providing services to local communities, particularly to those in need, as well as around the world, and often in remote regions.

Currently, there are more than 493 NPOs registered in the UAE (Source: MOCD) and subject to the supervision of the relevant competent authorities, such as Ministry of Community Development (MOCD - Federal jurisdiction), the Rulers of the individual Emirates (Emirate-level Ruler's Funds), the Islamic Affairs and Charitable Activities Department (IACAD - Dubai jurisdiction), and the International Humanitarian City (IHC - Dubai Free Zone jurisdiction).

The abuse of NPOs, and specially charities, is a serious risk that many countries are facing and are trying to combat. The UAE recognizes the risk of abusing NPOs; particularly in Terrorist Financing (TF).

In assessing the TF risk associated to NPOs, Reporting Entities may consider at least the factors relating the geographic area, the structure and organization, and the activity of NPOs. These are not static assessments. Factors change over time, depending on how circumstances develop, and how threats evolve.

To promote compliance with the AML/CFT Law and the fulfilment of the STRs requirements, the UAE FIU developed a list of indicators (or red flags) based on which there is reason to suspect the abuse of NPOs.

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