The Anti Money Laundering Network (AML Network) has officially served a Letter of Claim and Pre-Action Notice to the Financial Action Task Force (FATF) and its Executive Secretary, Violaine Clerc. The notice challenges the institutional integrity of the FATF’s February 2024 decision to remove the United Arab Emirates (UAE) from its “Grey List” (Enhanced Monitoring Status).
This formal correspondence establishes a procedural record of what AML Network identifies as a critical “Integrity Gap.” Despite the FATF’s certification of the UAE’s “substantial completion” of AML reforms, international enforcement data from 2024 to 2026 reveals that UAE-based networks continue to facilitate billions in illicit finance and sanctions evasion for sanctioned regimes.
The Failure of the “Two-Limb Test”
AML Network’s research asserts that the FATF bypassed its own mandatory methodology , which requires a jurisdiction to demonstrate not just legislative changes (Technical Compliance), but also real-world results.
The notice highlights that while the UAE was “white-listed,” it simultaneously functioned as a primary “Shadow Hub” for Russian and Iranian capital, directly contradicting the FATF’s “Substantial Effectiveness” ratings for Immediate Outcomes (IO) 3, 4, and 11.
Formal Demands for Disclosure
AML Network has formally requested that the FATF Secretariat provide the following information by March 02, 2026:
- Evidentiary Basis: A detailed technical justification for the UAE’s delisting despite conflicting intelligence from the UN Security Council and EU high-risk designations.
- Accountability Records: Identification of the decision-making bodies and representatives responsible for the final delisting approval.
“The global financial watchdog cannot operate in a vacuum of transparency,” the organization stated. “If the FATF ignores real-world sanctions data in favor of procedural box-ticking, it ceases to be a compliance instrument and becomes a diplomatic tool. This notice ensures that the FATF leadership is held accountable for the systemic risks now entering the global financial system through the UAE ‘Legal Bridge’.”
The full investigative report is available for public review at:
The Anti Money Laundering Network (AML Network) is an independent investigative watchdog dedicated to exposing the hidden networks of financial secrecy and illicit finance that threaten global security. By bridging the gap between open-data research and AML enforcement, AML Network provides the evidence needed to challenge institutional opacity and dismantle systems of corporate laundering.