Commercial Bank of Dubai PSC (CBD)

🔴 High Risk

The Commercial Bank of Dubai (CBD), a prominent commercial bank of dubai, operates as a full-service financial institution in the UAE, offering retail, corporate, and commercial bank of dubai trade finance services from its commercial bank of dubai head office in Dubai. Established in 1969, CBD has grown into a key player with branches like the commercial bank of dubai ajman branch, commercial bank of dubai fujairah branch, and commercial bank of dubai sharjah, serving clients across commercial bank of dubai locations including Deira, Bur Juman, and DIFC.

While no direct enforcement actions name CBD for commercial bank of dubai money laundering or commercial bank of dubai fraud, its exposure to trade-based laundering typologies in Dubai’s free zones positions it at the intersection of systemic Anti–Money Laundering (AML) challenges.​

This case holds significance in the global Anti–Money Laundering (AML) landscape, illustrating how even established banks like commercial bank of dubai psc face jurisdictional risk from UAE’s historical FATF grey-listing and gold/trade vulnerabilities, underscoring the need for robust Customer due diligence (CDD) and Know Your Customer (KYC) in high-risk hubs.​

Background and Context

Commercial Bank of Dubai history traces to its 1969 founding via Emiri Decree, initially as a joint venture with foreign banks like Commerzbank and Chase Manhattan, evolving into a public joint-stock company listed on the Dubai Financial Market in 2003 under ticker commercial bank of dubai cbd. By 2024, commercial bank of dubai total assets and commercial bank of dubai revenue reflected steady growth, driven by commercial bank of dubai mortgage products, Islamic banking, and trade finance, with commercial bank of dubai financial statements showing resilience amid UAE economic diversification.​

The commercial bank of dubai board of directors, led by Chairman H.E. Ahmad Abdulkarim Julfar, and the commercial bank of dubai management team including commercial bank of dubai executive management, oversee operations from the commercial bank of dubai headquarters.

Commercial bank of dubai psc shareholders include the Investment Corporation of Dubai (ICD, ~20%), Al Futtaim (~17-26%), and others like AW Rostamani, embedding commercial bank of dubai politically exposed person (PEP) links via government ties.​

Timeline markers include UAE’s 2022 FATF grey-listing for AML deficiencies, prompting sector-wide scrutiny, and CBD’s 2022 tech upgrades for name screening amid rising suspicious transaction reports in trade flows. No specific commercial bank of dubai suspicious transaction exposure led to controversy, but Dubai’s illicit trade ecosystem heightened baseline risks.​

Mechanisms and Laundering Channels

CBD’s commercial bank of dubai trade finance portfolio exposes it to trade-based laundering, where over/under-invoicing, phantom shipments, and misdescribed goods in free zones facilitate money laundering via letters of credit. Research flags Dubai’s gold sector for round-tripping to inflate credit limits, a typology relevant to CBD’s commodity finance amid commercial bank of dubai al quoz and FTZ activities.​

Potential channels include linked transactions through electronic funds transfer (EFT) in high-risk sectors like real estate (commercial bank of dubai ghaya residence) and cash-intensive business, though CBD’s commercial bank of dubai annual report claims mitigation via transaction monitoring. No evidence ties CBD to commercial bank of dubai shell company or commercial bank of dubai offshore entity use, but opacity in beneficial ownership for trade clients raises structuring risks.

Commercial bank of dubai beneficial owner disclosures for shareholders are public, yet client-side hybrid money laundering via layered EFTs remains a concern in UAE banking.​

UAE Central Bank enforcement since 2022 has fined banks for AML lapses in CDD, monitoring, and suspicious reporting, though no actions name Commercial Bank of Dubai Abu Dhabi Branch or others directly. CBD aligns with Federal Decree-Law No. 20/2018 on AML/CFT, emphasizing Know Your Customer (KYC) and FIU reporting in its policy.​

FATF recommendations on beneficial ownership and trade finance due diligence apply, post-grey-list removal in 2024, with UAE courts addressing laundering via special benches. CBD faces no commercial bank of dubai forced liquidation or blacklisting; instead, it invests in compliance tech for commercial bank of dubai careers in risk roles. Legal disputes like Commercial Bank of Dubai PSC v Al Sari involve debt recovery, not misconduct by the bank.​

Financial Transparency and Global Accountability

The absence of named cases belies UAE-wide gaps in financial transparency, where Dubai banks process flows from high-risk jurisdictions without full beneficial ownership visibility. CBD’s commercial bank of dubai investor relations and DFM listings promote disclosure, yet trade opacity challenges global standards.​

International watchdogs like FATF highlighted UAE supervision weaknesses, spurring cross-border data sharing reforms. CBD’s response includes board-level corporate governance oversight, aiding Anti–Money Laundering (AML) cooperation, though commercial bank of dubai net worth stability suggests contained impact. Lessons reinforce FATF’s trade-based laundering guidance for institutions like CBD.​

Economic and Reputational Impact

No scandal disrupted commercial bank of dubai financials, with steady commercial bank of dubai forbes-worthy performance and partnerships intact. Sector fines totaling AED370m+ signal caution, potentially affecting commercial bank of dubai jobs and client trust in branches like commercial bank of dubai dubai mall or commercial bank of dubai festival city.​

Broader effects include heightened de-risking in UAE trade finance, impacting commercial bank of dubai ras al khaimah and investor confidence, yet CBD’s commercial bank of dubai leadership maintained stability without stock volatility tied to AML issues.​

Governance and Compliance Lessons

Commercial Bank of Dubai CEO and commercial bank of dubai head of marketing operate under a three-lines-of-defense model, with the Board Risk Committee addressing cash-intensive business risks. Gaps, if any, mirror UAE peers: inadequate name screening for PEPs in trade chains.​

Post-grey-list, CBD enhanced controls via Ingenuous tech for anomaly detection, exemplifying corporate governance. Lessons stress perpetual KYC for commercial bank of dubai jumeirah clients and trade document verification.​

Legacy and Industry Implications

CBD’s profile influences AML in MENA banking, promoting tech-driven monitoring amid commercial bank of dubai kalba expansions. It underscores trade-based laundering red flags, shaping FATF-aligned reforms and peer benchmarking for commercial bank of dubai difc operations.​

No turning point for CBD, but it exemplifies resilience through financial transparency, influencing UAE’s delisting and global standards for hub banks.​

Commercial Bank of Dubai navigates elevated money laundering risks without direct violations, highlighting systemic UAE challenges in trade and gold. Core lessons affirm vigilant Anti–Money Laundering (AML), beneficial ownership scrutiny, and corporate governance to protect global finance integrity.​

Country of Incorporation

United Arab Emirates (UAE).​

  • Headquarters: Dubai, Emirate of Dubai, UAE.​

  • Primary operating country: UAE, with branches and services concentrated in Dubai and other emirates.​

  • Sector: Banking and financial services.​

  • Core activities: Retail banking, corporate and commercial banking, Islamic banking, treasury and investment services, and trade finance.​

  • Public joint stock bank listed on the Dubai Financial Market (DFM) since 2003.​

  • Originally established in 1969 by Emiri Decree as a joint venture with foreign banks, then restructured in 1982 into a national public shareholding company aligned with Dubai government economic strategy.​

  • Not a shell or front company; operates as a full‑service commercial bank subject to UAE Central Bank regulation and on‑exchange disclosure rules.​

(Observed risk exposure, not proven schemes specific to CBD)

  • Trade‑based money laundering (TBML) risk via letters of credit, guarantees, and other trade‑finance instruments in a jurisdiction with documented vulnerabilities in free trade zones, gold, and high‑risk commodities flows.​

  • Layering through cross‑border transfers routed via Dubai’s banking sector, where FATF and investigative reporting have flagged systemic exposure to sanctions evasion, corruption proceeds, and organized crime funds.​

  • Potential exposure to misuse of accounts in sectors such as real estate, gold, and corporate vehicles, common typologies in the UAE, although CBD publicly claims extensive controls to mitigate these risks.​

Major shareholders (direct significant stakes):

  • Investment Corporation of Dubai (ICD – Government of Dubai investment arm): approx. 20 percent.​

  • Al Futtaim Private Co. LLC: around 17–26 percent (various disclosures list c. 17.46–26.3 percent depending on reference date).​

  • Orient Insurance PJSC: about 8.84 percent.​

  • AW Rostamani Holdings: about 7.68 percent.​

  • Ghobash Trading & Investment Co. Ltd.: about 6.37 percent.​

  • Remaining shares widely held among UAE investors, with a one‑share‑one‑vote framework and a general cap of 20 percent per shareholder in the Articles of Association.​

Key individuals (board / senior figures – non‑exhaustive):

  • H.E. Ahmad Abdulkarim Julfar – Chairman of the Board, representing the Investment Corporation of Dubai’s interests.​

  • Other directors include representatives from major shareholder families and groups (e.g., Al Futtaim, AW Rostamani, Ghobash), serving three‑year board terms under the bank’s corporate governance framework.​

  • Senior risk and compliance leadership includes a Chief Risk Officer and a Money Laundering Reporting Officer, highlighted in vendor and governance material.​

    • Yes (by ownership/control nexus, not as an allegation). ICD is the sovereign investment arm of the Government of Dubai, and its board‑level representation means the bank is partly owned and influenced by a state‑linked entity associated with ruling‑family political exposure.​

    • Individual board members connected to major local families and government‑linked enterprises may qualify as PEPs or close associates under most AML definitions, although open sources do not frame them as subjects of corruption cases.​

  • CBD does not feature prominently in major public datasets such as the Panama Papers or Paradise Papers under its own name, and no large, named CBD‑centred leak‑driven investigation is visible in open sources as of 2025.​

  • The bank appears mainly in the context of the broader UAE banking system’s role in global illicit‑finance flows and sanctions‑evasion risk highlighted by FATF‑related commentary and investigative reporting on Dubai.​

  • Jurisdiction: UAE.

  • Risk characterisation: Medium–High.

    • FATF placed the UAE on its “grey list” in March 2022 due to strategic AML/CFT deficiencies, explicitly citing weaknesses in effective supervision, sanctions implementation, and money‑laundering investigations.​

    • The UAE was removed from the grey list in February 2024 after reforms, but analysts continue to flag elevated risk tied to Dubai’s role in gold trade, real estate, and free zones, which continue to impact banks like CBD.​

  • No clearly identified, public enforcement order directly naming Commercial Bank of Dubai for specific AML or TBML violations in 2024–2025 could be located in open sources.​

  • UAE Central Bank, however, has imposed sizeable AML‑related penalties on multiple unnamed local and foreign banks in recent years for failures in customer due diligence, monitoring, and reporting, underscoring systemic compliance gaps in the banking sector CBD operates within.​

  • CBD itself emphasizes a comprehensive AML/CTF programme, including board‑approved policies, risk‑based CDD, three lines of defence, and independent audit, and has publicised partnerships to enhance financial crime technology, suggesting a response to supervisory expectations.​

  • Active commercial bank, licensed by the Central Bank of the UAE and listed on the Dubai Financial Market under the ticker “CBD”.​

  • 1969 – Incorporation in Dubai by Emiri Decree of Sheikh Rashid bin Saeed Al Maktoum as a joint venture between Commerzbank, Chase Manhattan Bank, Commercial Bank of Kuwait and local UAE businessmen; foreign banks initially held around 78 percent.​

  • 1982 – Restructuring into a national public shareholding company, with the Government of Dubai (through later ICD structure) becoming a major shareholder and ownership shifting towards local strategic groups.​

  • 2003 – Listing on the Dubai Financial Market (DFM), increasing public float and bringing the bank under on‑exchange disclosure and governance standards.​

  • 2010s – Gradual expansion of retail, corporate, Islamic, and digital banking offerings, growth in trade finance and SME banking, and closer alignment with Dubai economic diversification objectives.​

  • 2019 – Publication of corporate governance material highlighting the Board Risk and Compliance Committee’s role in overseeing AML/CFT, conduct and compliance risk.​

  • 2020 – FATF evaluation and international commentary highlight UAE’s limited effectiveness in prosecuting money laundering and sanctions evasion, putting Dubai‑based banks, including CBD, under heightened scrutiny.​

  • 2022 – Public announcement of CBD’s partnership with Ingenuous to strengthen financial crime controls, fraud detection, and AML monitoring using advanced analytics technology.​

  • 2022–2024 – UAE placed on and subsequently removed from FATF grey list, during a period in which the UAE Central Bank levies significant fines on multiple banks for AML failures, signalling escalated supervisory expectations for institutions such as CBD.​

  • 2024–2025 – CBD’s annual reporting and policy documents reiterate its AML/CTF policy framework, risk‑based approach, and governance structures, underlining the importance of financial‑crime compliance to its risk appetite.​

  • Trade‑based money laundering (over/under‑invoicing, phantom cargo, mis‑description).

  • Layering via cross‑border transfers through Dubai financial system.

  • Potential misuse of corporate accounts connected to gold, real estate, and FTZ trading firms.

MENA, GCC, UAE, Dubai.

High (UAE systemic risk, high‑risk sectors, historic FATF grey‑listing), with partial mitigation via visible investments in compliance and technology.​

Commercial Bank of Dubai PSC (CBD) ​

Commercial Bank of Dubai PSC (CBD)
Country of Registration:
United Arab Emirates
Headquarters:
Dubai, United Arab Emirates ​
Jurisdiction Risk:
High
Industry/Sector:
Banking / Financial Services / Trade Finance ​
Laundering Method Used:

– Trade-based money laundering (TBML) via letters of credit, over/under-invoicing in FTZs/gold ​
– Layering through cross-border transfers and high-risk sector accounts (real estate, commodities) ​

Linked Individuals:

– H.E. Ahmad Abdulkarim Julfar (Chairman, ICD rep – PEP-linked) ​
– Al Futtaim family/group (17-26% ownership) ​
– AW Rostamani Holdings reps (7.68%) ​
– Ghobash Trading reps (6.37%)

Known Shell Companies:

N/A

Offshore Links:
Estimated Amount Laundered:
Not applicable (no named CBD-specific laundering case; sector-wide UAE TBML risks in hundreds of millions)
AML Network Risk Rating:
🔴 High Risk
Quick Links:
Popular Pages:
Disclaimer & Legal:
Facebook-f Twitter Youtube Pinterest-p Instagram Tiktok
© 2025 AML Network. – All Rights Reserved.