The travel rule requires a virtual asset service provider sending a transfer to collect and transmit required information about the originator and beneficiary, such as names and account or wallet identifiers, to the receiving provider, and requires the receiving provider to obtain and check that information. Firms must have procedures for transfers where information is missing or incomplete, for counterparties that are unregulated or unknown, and for transfers involving unhosted wallets. Records must be kept and made available to supervisors. The precise requirements depend on the regulator and the rulebook that apply, so we review them for each firm.

Federal Decree-Law No. 10 of 2025 replaced the 2018 anti-money laundering law and modernised the framework for combating money laundering, terrorist financing and proliferation financing. It reinforced the obligations of financial institutions and virtual asset service providers, strengthened penalties and supervisory powers, and reflected FATF standards more closely. Implementing regulations and regulator guidance add detail. Virtual asset firms should review their policies, risk assessments, training and governance against the new law, rather than assuming that a programme built under the earlier law remains sufficient. We help firms carry out a gap analysis and update their documents and travel rule procedures.

No. A technology solution can help a firm exchange information with counterparties and keep records, but compliance depends on how the firm uses it. The firm must decide which counterparties it will deal with, how it verifies that they are legitimate regulated providers, what it does when data is missing or does not match, how it treats unhosted wallets and how it monitors the quality of information over time. Regulators will expect written policies, trained staff, management oversight and testing. We help firms set these elements around their chosen travel rule solution and review vendor contracts.

Nationality alone should not determine risk, and many Bangladeshi customers in the UAE are long-term residents with legitimate income. However, firms should understand that Bangladesh Bank has warned that virtual currency transactions are not authorised in Bangladesh, and that funds moving to or from Bangladesh outside formal channels may breach foreign exchange law. A firm's risk assessment should consider residence, source of funds, use of informal remittance channels and links to accounts in Bangladesh. Policies on serving Bangladesh residents should be clear. We help firms design proportionate, documented approaches that avoid both weak controls and unfair exclusion.

If a counterparty does not send required information, or the information is incomplete or inconsistent, the receiving firm must follow its procedures, which may involve requesting the missing data, delaying the credit, returning the transfer or rejecting it, and considering whether a suspicious transaction report is needed. Repeated failures by a counterparty should lead the firm to reassess the relationship and possibly restrict or end it. Firms should document their decisions in each case. We help design escalation paths and decision criteria so that staff act consistently and the firm can explain its approach to its regulator.

A report should be filed with the UAE Financial Intelligence Unit when the firm suspects, or has reasonable grounds to suspect, that funds are proceeds of crime or linked to terrorist financing or other prohibited activity, including attempted transactions. Reports are filed through the designated platform, and the firm must avoid tipping off the customer. Delays in reporting are treated seriously. Firms should have clear internal reporting lines to the money laundering reporting officer and records of decisions not to report. We advise on difficult reporting decisions, particularly where facts involve several jurisdictions or travel rule gaps.

UAE law requires firms to implement targeted financial sanctions without delay, including freezing funds and virtual assets of designated persons and reporting to the competent authorities. Firms must screen customers, counterparties and, where possible, wallet addresses against relevant lists, and many also consider United States, United Kingdom and European Union sanctions for commercial or banking reasons. Blockchain analytics tools help identify exposure to sanctioned addresses. We advise on screening programmes, handling of potential matches, freezing procedures and reporting, and on the interaction with travel rule data and customer communication obligations.

The firm should treat the findings seriously, understand their root causes, and respond with a realistic remediation plan that sets clear actions, owners and deadlines, supported by board oversight. In some cases an independent review or look-back exercise may be required. Communication with the regulator should be accurate and timely, and progress should be documented. Weaknesses in onboarding, monitoring, travel rule processes and suspicious transaction reporting are common findings. We help firms prepare responses, design remediation, oversee reviews and, if enforcement is threatened, represent them with the regulator.