The Anti Money Laundering Network (AML Network) has officially served a formal notice to Tiff Macklem, Governor of the Central Bank of Canada, regarding what it describes as a critical procedural failure in the February 2024 decision by the Financial Action Task Force (FATF) to remove the United Arab Emirates from its Enhanced Monitoring (“Grey List”).
The notice formally establishes a record of concern that the UAE’s delisting may have been granted despite unresolved systemic effectiveness failures. AML Network asserts that the decision created a supervisory risk for global correspondent banking systems by potentially signaling compliance without fully verified enforcement outcomes.
The Supervisory Contradiction
AML Network’s communication raises a central question: on what evidentiary basis was a “Substantial Effectiveness” rating accepted when international sanctions activity involving UAE-based networks reportedly escalated following the delisting?
The organization argues that international “white list” status must reflect field-verified enforcement results rather than procedural or technical completion benchmarks alone. Any divergence between certification and post-delisting enforcement data, it contends, creates systemic credibility concerns.
Due Diligence and Domestic Risk Exposure
The notice further warns that premature removal from enhanced monitoring may influence domestic financial institutions to recalibrate their due diligence posture. If international certification is interpreted as reduced risk, it could inadvertently lower safeguards within national banking systems and increase exposure to illicit capital flows.
Given Canada’s participation in the G20 Finance Track and its systemic risk mitigation mandate, AML Network states that supervisory vigilance is essential when international standards bodies issue high-impact determinations.
The “Two-Limb Test” and Methodological Breach
AML Network asserts that FATF methodology requires jurisdictions to demonstrate both Technical Compliance and proven operational effectiveness — commonly referred to as the “Two-Limb Test.”
The notice questions whether the UAE satisfied this effectiveness threshold at the time of delisting, arguing that certification absent measurable enforcement durability undermines the integrity of the evaluation framework itself.
Formal Demands for Action
AML Network has formally requested that Canada’s delegation to the 2026 FATF Plenary place the following items on the official agenda:
A Governance Audit: An independent investigation into the 2024 UAE assessment process to restore methodological credibility.
A Technical Risk Reassessment: A formal review of the UAE’s status incorporating post-delisting illicit finance and sanctions data.
Additionally, the organization has requested formal acknowledgment within 48 hours and a substantive written response addressing the supervisory, due diligence, and methodological questions outlined in the notice.
“The integrity of the global financial system depends on transparent oversight and proven effectiveness,” the organization stated. “International AML certification must be grounded in measurable enforcement outcomes, not procedural formalities.”
The full investigative report is available for public review at: