2.3.1.3 Currency Exchanges

Effective from 27/9/2021

Cash-intensive businesses may include currency exchanges as legitimate providers of services. Currency exchanges, however, can also be an attractive vehicle that illicit actors seek to exploit to enter the financial system and transfer their funds. According to the FATF, the simplicity and certainty of currency exchanges transactions and the anonymity and portability of cash make them attractive to money laundering and the financing of terrorism and illegal organisations.⁵ Once the money has been exchanged, it is difficult to trace its origin. There are two different ways to perform a currency exchange: (1) the use of cash to exchange and transfer the funds; or (2) the use of the internet to perform the currency exchange and transfer the funds to a bank account.

•	Potential Risk Indicators:
	o	Significant and/or frequent local or foreign currency exchanges.
	o	Opening of foreign currency accounts with no apparent business or economic purpose.
	o	Customers who know little about or are reluctant to disclose details about the payee, or customers or parties with no apparent ties to the destination country.
	o	Suspicion that the customer is acting on behalf of a third party but not disclosing it.
	o	Transactions involving charities and other non-profit organizations, which are not properly licensed or registered. It is reminded that when opening any accounts for non-profit organisations, LFIs must obtain an original signed letter from the Ministry of Community Development for opening accounts to collect donations and an authorization from the UAE Red Crescent for conducting financial transfers out of the UAE through some of these accounts.
	o	Customers who use false identification or offer different identifications on separate ccasions.
	o	Customers who receive transfers in seasonal patterns or transactions in a pattern consistent with criminal proceeds.

⁵ FATF “Money Laundering through Money Remittance and Currency Exchange Providers” (June 2010), available at: https://www.fatf-gafi.org/media/fatf/ML%20through%20Remittance%20and%20Currency%20Exchange%20Providers.pdf