Cross-Border Crypto

🔴 High Risk

The rise of cryptocurrency in the Gulf, especially in the UAE and Saudi Arabia, has created opportunities for sophisticated cross-border money laundering through Gulf wallet networks. Illicit actors exploit weak and uneven regulations, using stablecoins, unlicensed peer-to-peer platforms, and informal channels to obscure transactions. Despite regulatory advances like the UAE’s VARA and Saudi Arabia’s Project Aber, enforcement gaps remain. This case highlights the urgent need for stronger regional cooperation and real-time monitoring to address laundering risks in the Gulf’s rapidly growing crypto ecosystem.

The cross-border crypto laundering case involving Gulf wallet networks in the UAE and Saudi Arabia highlights a significant challenge amid the Gulf’s ambition to be global crypto hubs. Illicit actors exploit the rapid growth of digital asset adoption alongside nascent and sometimes uneven regulatory oversight to launder substantial illicit funds. Techniques involve sophisticated layering using stablecoins, informal P2P networks, and rapid transnational transfers that obscure the source and destination of funds. While the UAE has made notable regulatory strides via VARA and FSRA, Saudi Arabia’s cautious but evolving engagement through pilot projects like Project Aber aids in risk mitigation. Nonetheless, laundering persists due to the region’s active informal networks and the complex interplay between licensed and illicit financial channels. This case underscores the critical need for enhanced cross-border AML cooperation, real-time transaction monitoring, and stricter regulation enforcement within Gulf crypto ecosystems to prevent money laundering and associated financial crimes.

Countries Involved

United Arab Emirates (UAE) and Saudi Arabia

Reported in multiple analyses and regulatory reports from 2023 to mid-2025

Bitcoin (BTC), Ethereum (ETH), Tether (USDT), USD Coin (USDC), other altcoins common in the Gulf

Money laundering through cross-border cryptocurrency transactions exploiting digital wallets and crypto exchanges within GCC jurisdictions, notably UAE and Saudi Arabia

Unlicensed peer-to-peer (P2P) platforms, informal money transfer networks, Virtual Asset Service Providers (VASPs) operating in varying compliance states, commercial banks involved in testing digital currency pilots, and sometimes politically exposed persons (PEPs) linked through complex transaction layering.

Yes. Various reports indicate potential involvement of PEPs in layering and integration phases of laundering via Gulf crypto wallets and exchanges, leveraging regulatory gaps and network opacity.

Gulf wallet networks facilitate laundering through complex methods including:
Use of multiple wallet addresses to obscure audit trails
Cross-border transaction layering using stablecoins (USDt and USDC), which provide liquidity and rapid conversion
Peer-to-peer unlicensed exchanges and informal remittance channels circumventing traditional AML controls
Integration of digital assets into the formal banking system through licensed entities with inadequate monitoring
Exploiting regulatory divergence and sandbox environments in UAE and Saudi Arabia to mask illicit financial flows

While precise figures remain undisclosed due to operational secrecy, regional crypto transaction volumes have surged beyond several billion dollars quarterly, with a significant portion suspected tied to illicit laundering activities due to high volumes through informal channels and weak AML enforcement in parts of the region.

Analysis reveals that Gulf wallet networks act as conduits for illicit funds moving between UAE and Saudi Arabia, leveraging the region’s burgeoning crypto ecosystem and nascent regulatory frameworks. Transaction flows often initiate in peer-to-peer informal wallets, transit through multiple address exchanges often denominated in stablecoins for value preservation, and subsequently get converted or integrated via institutional financial infrastructure being tested under initiatives like Project Aber—a joint Saudi-UAE central bank digital currency pilot. This blending of private, public, and decentralized channels complicates detection. UAE’s Virtual Assets Regulatory Authority (VARA) and Abu Dhabi’s Financial Services Regulatory Authority (FSRA) have intensified scrutiny, yet enforcement gaps allow laundering networks to persist due to the fast-evolving digital assets landscape juxtaposed with cautious regulatory approaches in Saudi Arabia.

UAE has implemented comprehensive licensing regimes for VASPs, AML frameworks aligned with international standards, and is actively overseeing digital assets through Dubai’s VARA and Abu Dhabi’s FSRA.
Saudi Arabia, while cautious, maintains regulatory sandboxes and pilot projects such as Project Aber that include anti-money laundering measures embedded in cross-border CBDC experiments.
Joint efforts include coordination between Saudi Arabia’s Saudi Arabian Monetary Authority (SAMA) and the UAE’s Central Bank to develop secure, compliant cross-border platforms.
However, enforcement against unlicensed P2P crypto platforms and informal remittance channels remains challenging, demanding continuous regional cooperation and technological upgrades in AML surveillance.

Cross Border Crypto
Case Title / Operation Name:
Cross-Border Crypto Laundering via Gulf Wallet Networks
Country(s) Involved:
Saudi Arabia, United Arab Emirates
Platform / Exchange Used:
Unlicensed peer-to-peer (P2P) platforms, VASPs under varying compliance, informal remittance channels, licensed crypto exchanges
Cryptocurrency Involved:

Bitcoin (BTC), Ethereum (ETH), Tether (USDT), USD Coin (USDC), other altcoins common in the Gulf

Volume Laundered (USD est.):
Billions of dollars quarterly (estimated; exact figures undisclosed)
Wallet Addresses / TxIDs :
Multiple wallet addresses used across layered transactions (specific addresses undisclosed)
Method of Laundering:

Use of multiple wallet addresses to obscure audit trails; layering via stablecoins (USDT, USDC); cross-border transaction layering; peer-to-peer unlicensed exchanges; integration into formal banking via licensed entities with limited monitoring; exploiting regulatory divergences and sandbox environments

Source of Funds:

Corruption, tax fraud, cybercrime, politically exposed persons (PEPs) linked sources

Associated Shell Companies:

Not publicly disclosed; laundering involves complex layering possibly involving shell companies

PEPs or Individuals Involved:

Politically exposed persons (PEPs) reportedly involved in layering and integration phases through Gulf crypto networks

Law Enforcement / Regulatory Action:
UAE implemented licensing regimes and AML frameworks via VARA and FSRA; Saudi Arabia operating regulatory sandboxes and pilot projects (Project Aber); ongoing regional coordination and efforts to oversee unlicensed P2P platforms and informal channels
Year of Occurrence:
2023–2025 (reported across multiple analyses and regulatory reports)
Ongoing Case:
Ongoing
🔴 High Risk