If you follow new developments in anti-money laundering legislation, you know that the united Arab emirates (UAE) has updated its AML laws to include what amounts to what we Americans call Willful Blindness, where liability can arise where a person either actually knew, or it would have been reasonable for them to have known, about the illicit nature of funds.
Now pair that with an additional provision that provides for personal liability: Managers of legal entities can now also be subject to personal criminal liability in certain circumstances. How this will be interpreted will be of interest to those leaders of companies that have sold Eastern Caribbean passports for up to 60% discounts, which are illegal under the jurisdictions that issue them, and could constitute a Predicate Offense under the UAE AML/ CFT laws.
Will the UAE finally crack down on what has been a totally unregulated industry? Only time will tell, but we will be watching.
No comments:
Post a Comment
Note: Only a member of this blog may post a comment.