UAE Illicit Network Index

Bypassing sanctions and criminal activity

This dataset maps sanctioned entities (companies and individuals) in the UAE and their connections, which span across multiple jurisdictions, such as (but not limited to) Russia, Iran, China, Pakistan, and Ireland. The sanctioned entities have been designated for bypassing international sanctions, drug trafficking, terrorism, and money laundering.

The dataset reflects UAE's role as a nest for international illicit networks. Emirati companies and real estate are used to transfer funds and goods, while a number of individuals with high-risk links maintain residence in the country.

Due to the opaque nature of the political and media landscapes in the UAE, it has been difficult to identify a large number of politically exposed persons (PEPs) with explicit links to sanctions or corruption. Investigations and leaks known to Evidencity do not mention specific individuals but rather discuss the UAE as a regime harbouring corruption and crime. Thus, only a handful of PEPs are part of the current dataset. No explicit allegations or accusations were identified.

Investigations and leaks known to Evidencity do not mention specific individuals but rather discuss the UAE as a regime harbouring corruption and crime.

Map Highlights

• A large network of UAE-based companies have assisted Iranian petrochemical companies bypass international sanctions. These are often shell companies. Certain entities maintain links to Russia.

• UAE-based companies have assisted Russian companies bypass international sanctions and gain access to specific telecommunications and other equipment, which support Russia's military. A Chinese network of companies was also identified, but it was excluded due to the focus on the UAE. Certain links identified lead back to Iran and most specifically directly to the Ministry of Defence and the Iranian army.

• The dataset maps UAE's exposure to international terrorist networks such as Hamas, Hezbollah and Al-qaeda as well as their subsequent connection to international money launderers, such as the Altaf Khanani MLO, which was behind large Forex scams and illicit transactions in Pakistan.

• Drug traffickers have taken shelter in Dubai by moving their residence and properties. Namely, the Kinahan cartel appears to hide in the UAE.

• Relatives of notorious Russian oligarch Alisher Usmanov - a close Putin ally - maintain residence and activities in the UAE. They seem to also maintain former links to British football teams in which Usmanov was also involved as an investor.

Collecting data to create an illicit network dataset is challenging, time consuming, and requires manual research and documentation. There is no other similar publicly accessible dataset available.