Money laundering is, at its core, a problem of disguise. Criminals generate wealth through illegal activity, such as drug trafficking, fraud, corruption, tax evasion, and then face a practical challenge: how do you spend or invest money that cannot be explained? The answer, developed and refined over decades, follows a recognisable three-stage model: placement, layering and integration.
Understanding these three stages is not academic. For compliance teams, regulators and financial crime investigators, recognising where a transaction or relationship sits in the laundering cycle determines which controls apply, which red flags to look for, and what reporting obligations may be triggered.
This guide explains each stage in depth, with specific examples drawn from the UAE's real estate, gold and virtual asset sectors – three industries that have faced sustained scrutiny from domestic regulators and international bodies including the FATF.
What Is Money Laundering? A Quick Recap
Money laundering is the process by which the proceeds of crime are transformed to appear legitimate. Under UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, money laundering includes acquiring, possessing, using, converting, transferring or concealing funds derived from a predicate offence, knowingly or where the person ought reasonably to have known.
The predicate offences from which laundered funds originate include drug trafficking, organised crime, bribery and corruption, tax crimes, human trafficking, fraud, cybercrime and terrorist financing. The common thread is that the funds are “dirty”, their true origin would expose the owner to criminal liability or asset forfeiture, and the launderer’s goal is to make them “clean” enough to spend, invest or transfer without scrutiny.
The UN Office on Drugs and Crime (UNODC) estimates that between 2% and 5% of global GDP, roughly USD 800 billion to USD 2 trillion, is laundered annually. The UAE’s position as a major trade, financial and real estate hub makes it a high-value target. |
Stage 1 PLACEMENT | Getting dirty money into the financial system The most vulnerable — and most detectable — stage of the laundering cycle |
Stage 1: Placement
Placement is the first and most dangerous stage for the launderer. This is the point at which illicit cash, the physical or digital proceeds of crime, enters the legitimate financial system for the first time. It is dangerous because this is where the money is most closely associated with the underlying criminal activity, and where detection risk is highest.
The core challenge at this stage is volume: large amounts of cash are difficult to deposit, transport or invest without triggering suspicion. Laundering techniques at the placement stage are designed to overcome this.
Common Placement Techniques
Smurfing (structuring): breaking a large sum into multiple smaller deposits, often just below reporting thresholds, made by multiple individuals (“smurfs”) across different branches or institutions to avoid detection. In the UAE, the Central Bank’s cash transaction reporting threshold is AED 55,000.
Laundering cash through a legitimate cash-heavy business: mixing criminal proceeds with the legitimate revenues of a cash-heavy business such as a restaurant, car wash or retail outlet. The business’s cash takings are inflated to absorb the dirty money.
Currency exchange and hawala: converting cash into foreign currency or using informal value transfer systems (hawala) to move funds across borders without a formal banking trail.
Real estate cash deposits: paying reservation fees, deposits or even full purchase prices in cash through property transactions in jurisdictions with weak oversight.
UAE-Specific Placement Examples
The UAE’s large informal economy, high cash usage in certain sectors, and historically limited beneficial ownership transparency created conditions that attracted placement-stage activity. Documented examples and typologies from UAEFIU and FATF mutual evaluation reports include:
Cash payments for gold at Dubai’s gold souk, with dealers historically operating without robust KYC requirements, a vulnerability addressed by Ministry of Economy guidance from 2021 onwards
Crypto-to-cash and cash-to-crypto conversions through unregulated peer-to-peer platforms operating before VARA’s licensing regime came into effect
Inflated cash payments for real estate reservation fees, with the excess refunded by cheque to create a clean paper trail
⚠️ Placement Red Flags for Compliance Teams • Multiple cash deposits just below reporting thresholds (structuring pattern) • New customer depositing large cash amounts with no plausible source of wealth • Customer paying for high-value goods or property entirely or primarily in cash • Transactions routed through multiple branches of the same institution on the same day • Reluctance to provide identification or source-of-funds documentation • Use of multiple third parties to make payments on behalf of an undisclosed principal |
Stage 2 LAYERING | Obscuring the trail through complexity and distance The stage where legal structures, jurisdictions and transactions multiply |
Stage 2: Layering
Layering is the most complex stage of the money laundering process. Once funds have entered the financial system, the launderer’s objective is to put as much distance as possible between the funds and their criminal origin. This is achieved by creating a web of transactions, legal structures and jurisdictions that is difficult for investigators to untangle.
The three most significant layering vehicles, such as smurfing at scale, shell companies and offshore banking deserve individual attention.
Smurfing at Scale
What begins as a placement technique (small deposits) extends into layering when the funds are then moved between multiple accounts, currencies or jurisdictions. A network of individuals may transfer funds between accounts in a pattern designed to frustrate transaction monitoring: the funds appear to move for legitimate commercial reasons but are in fact orbiting between controlled accounts.
Shell Companies
A shell company is a legal entity, typically a limited liability company, holding company or special purpose vehicle that has no genuine commercial activity. It exists solely on paper, often in a jurisdiction with limited transparency requirements, and is used to hold assets, receive payments or sign contracts in a way that conceals the true beneficial owner.
Shell companies are not inherently illegal. Many are used for legitimate tax planning, holding structures or joint venture purposes. Their misuse in money laundering arises when they are layered, a UAE company owned by a BVI company owned by a Cayman trust owned by a Panamanian foundation, such that identifying the natural person who ultimately owns or controls the structure becomes practically impossible.
The UAE significantly strengthened its beneficial ownership register requirements from 2020 onwards, requiring most onshore and free zone companies to maintain and file beneficial ownership registers. This directly targets the shell company layering problem.
Offshore Banking
Moving funds through bank accounts held in multiple jurisdictions, particularly those with strong secrecy laws, limited information-sharing agreements or weak AML supervision is a classic layering technique. Each international wire transfer adds a layer of distance and makes the paper trail more fragmented.
Common offshore jurisdictions used in UAE-linked layering schemes have included the British Virgin Islands, Seychelles, Panama, Marshall Islands and, historically, Cyprus and Malta. The global expansion of FATF membership and the Common Reporting Standard (CRS) for automatic tax information exchange has significantly reduced the utility of traditional offshore secrecy, though gaps remain.
⚠️ Layering Red Flags for Compliance Teams • Complex corporate structures with no clear commercial rationale, multiple holding entities across different jurisdictions • Frequent international wire transfers to or from high-risk jurisdictions with no evident business purpose • Customer unable or unwilling to identify the ultimate beneficial owner of a corporate entity • Round-tripping: funds sent abroad and returned to the UAE appearing as “foreign investment” • Back-to-back loans between related entities – funds lent to an affiliate and repaid as “loan repayments” • Rapid in-and-out movement of funds through an account with no intermediate business activity • Use of legal professionals, notaries or company service providers to interpose additional layers |
Stage 3 INTEGRATION | Re-entering the economy as apparently legitimate wealth The final stage — and often the hardest to detect |
Stage 3: Integration
Integration is the final stage, at which the laundered funds re-enter the legitimate economy in a form that is indistinguishable, or very difficult to distinguish, from lawful wealth. By this point, the paper trail created during the layering stage has done its work: the funds appear to have a legitimate origin.
The key feature of the integration stage is the normalization of illicit funds. The launderer begins to spend, invest and display wealth in ways that appear consistent with their stated business activities or income. Detection at this stage requires intelligence, not just transaction monitoring: the individual transactions may look entirely routine.
Common Integration Techniques
Real estate investment: purchasing high-value property with funds that appear to originate from a legitimate corporate vehicle or foreign investment, the proceeds of which can then be extracted as rental income or capital gains on sale
Luxury asset purchases: buying yachts, aircraft, jewellery, watches or artwork through dealers that historically lacked robust AML controls
Business investment: acquiring stakes in or establishing legitimate businesses, which then generate real income that mixes with the laundered funds
Loan-back schemes: the launderer deposits funds into a foreign account and then takes a “loan” from that account, repaying it with interest, creating both a legitimate-looking fund source and a tax deduction
Invoice fraud and trade-based money laundering: over- or under-invoicing international trade transactions to move value across borders under the cover of legitimate commercial activity
How Each Stage Manifests in UAE Sectors
Three sectors have been consistently highlighted in UAE-specific AML risk assessments and FATF typology reports: real estate, gold and precious metals, and virtual assets. The table below maps how each stage of the laundering cycle manifests across these sectors.
Sector | Placement | Layering | Integration |
Real Estate | Cash deposits for reservation fees; third-party payments | Rapid buy-sell cycles; inflated valuations; offshore buyer SPVs | Clean title deeds; rental income; equity refinancing |
Gold & Precious Metals | Buying gold with cash; converting cash across dealers | Selling gold abroad; re-melting into different forms | Selling refined gold for wire transfer proceeds |
Crypto / Virtual Assets | Converting cash via P2P; mixers and non-KYC exchanges | Chain-hopping; DeFi swaps; privacy coins | Converting to stablecoins; withdrawing via compliant exchanges |
Real estate is the UAE’s highest-profile AML vulnerability at the integration stage. A property purchased through a layered offshore structure produces rental income, capital appreciation and a bankable asset that looks entirely legitimate and whose criminal origin may never be traced without a full investigation of the purchase chain.
Detection Techniques at Each Stage
Effective AML programmes are designed to detect and disrupt laundering at each stage of the cycle, using a layered combination of controls.
At Placement
Cash transaction reporting (CTR): mandatory reporting of cash transactions above AED 55,000 to the UAEFIU via goAML
Structuring detection: transaction monitoring rules that flag multiple sub-threshold cash transactions by the same customer or connected individuals
Source of funds verification: requiring customers to evidence the legitimate origin of large cash deposits or payments at onboarding and for significant transactions
Physical cash controls: cash declaration requirements at UAE ports of entry, enforced by Dubai Customs and Federal Customs Authority
At Layering
Beneficial ownership verification: identifying and verifying the ultimate beneficial owner (UBO) of corporate customers, required under CBUAE, DFSA and FSRA frameworks and screening against sanctions and PEP lists
Network analysis: using transaction monitoring systems to map relationships between accounts and identify circular fund flows or concentration patterns
Correspondent banking due diligence: enhanced scrutiny of funds received from or sent to high-risk jurisdictions or counterparty banks with weak AML controls
Legal structure scrutiny: challenging the commercial rationale for complex holding structures; requesting corporate organigrams and notarised UBO declarations
At Integration
Source of wealth verification for high-value transactions: particularly in real estate, private banking and luxury asset sectors, understanding how a customer accumulated their overall wealth not just the source of a specific payment
Adverse media and intelligence screening: identifying customers or connected parties with negative news linking them to financial crime, corruption or sanctions
Suspicious transaction reporting (STR): where integration-stage activity is identified, filing a goAML STR with the UAEFIU without tipping off the customer
Asset freeze and law enforcement referral: where criminal funds are identified, working with UAE prosecutors and the AMLSCU to support restraint and confiscation action
Famous Money Laundering Cases & What They Teach Us
1MDB. Layering Through Global Financial Institutions (2009–2015)
The 1Malaysia Development Berhad scandal involved the theft and laundering of approximately USD 4.5 billion from a Malaysian state investment fund. The funds were layered through a network of shell companies, offshore accounts and international banks, including institutions in Singapore, Switzerland, Luxembourg and the United States before being integrated into luxury real estate in New York and Los Angeles, high-end jewellery, artwork and the financing of the Hollywood film The Wolf of Wall Street.
What it teaches: layering works by exploiting gaps between jurisdictions. Banks that processed funds failed to look beyond the immediate transaction to the source of wealth. The case led to USD 3.9 billion in global settlements and triggered regulatory overhauls across multiple jurisdictions.
Danske Bank Estonia. Volume Concealment Through a Branch Network (2007–2015)
Approximately EUR 200 billion flowed through Danske Bank’s Estonian branch from non-resident accounts, mainly from Russia and other former Soviet states, over an eight-year period. The funds were moved through accounts held in the names of shell companies and then dispersed into the global financial system through correspondent banking relationships.
What it teaches: placement and layering can occur at industrial scale when internal controls are weak and local branches are inadequately supervised. The case resulted in the closure of the Estonian branch, the resignation of senior management, and multi-billion-dollar regulatory proceedings.
UAE Gold Sector. Trade-Based Laundering (Multiple Cases)
A series of FATF and UNODC reports have documented how gold has been used as a layering and integration vehicle in the UAE. In documented schemes, criminal proceeds from Latin American drug trafficking were used to purchase gold in the US, which was then exported to UAE refineries, re-melted, and sold on the legitimate market for clean proceeds. The complexity of the supply chain, spanning multiple countries, commodities and counterparties, made tracing the original criminal funds extremely difficult.
What it teaches: trade-based money laundering exploits the legitimate complexity of international commerce. For compliance teams in the commodities sector, understanding the full supply chain not just the immediate counterparty is essential.
Money laundering follows predictable patterns, but those patterns only become visible when compliance programmes are designed to look for them at every stage of the cycle. B-AML works with regulated businesses across the UAE to build and test AML frameworks that detect suspicious activity before it becomes a regulatory problem. |
