Why AML in MENA Logistics Demands More Than the Minimum  

Five years ago, a logistics CEO might’ve dismissed AML as “the bank’s problem”. 

Today, that mindset could land them in a Dubai courtroom explaining why their trucks moved gold bars for sanctioned entities.  
  
With rising regulatory scrutiny, cross-border complexity, and evolving financial crime tactics, logistics firms in MENA can no longer treat AML as a low-priority task. The risks now include steep fines, reputational damage, and lost contracts.  

This article explores:  

• Key AML regulations reshaping MENA Logistics   
• Why logistics firms face rising financial crime exposure  
• Essential Steps for Effective AML Compliance   
• How Cedar Rose supports AML success in logistics 
   

Key AML Regulations Reshaping MENA Logistics   

Driven by global Financial Action Task Force (FATF) standards and the Middle East and North Africa Financial Action Task Force (MENAFATF), the region is experiencing a major shift in anti-money laundering (AML) compliance.  

The United Arab Emirates (UAE) leads the region with Federal Law No. 20 of 2018, which mandates risk-based AML/CFT (anti-money laundering and counter-financing of terrorism) programs and designated compliance officers. This framework was key to the UAE’s removal from the Financial Action Task Force (FATF) Grey List. Saudi Arabia takes a similar rigorous stance through dual AML and terrorism financing laws, which impose strict compliance on high-risk sectors like logistics.  

Egypt has advanced its AML framework, with updates from the Central Bank of Egypt (CBE) and expanded oversight from the Financial Regulatory Authority (FRA). Resource constraints and technical capacity limitations impact implementation effectiveness. Logistics operators face heightened expectations for customer due diligence (CDD), reporting, record-keeping, and cross-border transaction monitoring. Enforcement is led by the Egyptian AML and Terrorist Financing Unit.  

In Morocco, FATF's 2022 high-risk classification prompted major reforms. While existing legislation focuses on anti-terrorism and money laundering, regulatory gaps remain. The government has issued detailed AML guidance and partnered with the EU Global Facility to strengthen compliance. Trade-based money laundering (TBML) remains poorly understood, making logistics companies particularly vulnerable to regulatory scrutiny. Morocco's coordination with the UAE on AML/CFT signals increased regional alignment impacting cross-border trade.  
  
Across the region, logistics firms must now meet expanded due diligence requirements. These include verifying beneficial ownership, monitoring high-risk clients, and profiling customers. Firms must also screen transactions, check for sanctions and politically exposed persons (PEPs), review adverse media, and detect trade-based money laundering (TBML) risks. Cross-border operations create jurisdictional complexities requiring harmonised documentation.   

Technology is central to AML compliance in MENA logistics. AI, machine learning, and automation enhance threat detection, customer profiling, and transaction monitoring. Compliance costs vary by firm size and jurisdiction, with smaller operators facing greater challenges. Firms handling digital payments must also meet Virtual Asset Service Provider (VASP) requirements. However, legal fragmentation and inconsistent timelines across MENA complicate cross-border operations, highlighting the need for harmonised documentation and oversight.    

With increasing exposure to cross-border financial flows, logistics firms face stricter enforcement.   
Regulators are tightening their grip, issuing steep fines and holding executives personally accountable. This mandates a shift to technology-led compliance, demanding significant investment for continued competitiveness and operations.  
 

Why MENA Logistics Firms Face Rising Financial Crime Exposure  

Rising financial crime exposure stems from three converging forces: criminal innovation, operational vulnerabilities, and regulatory scrutiny. Criminal networks exploit AI and cyberattacks to embed illicit activities within fast-moving supply chains, outpacing traditional compliance systems.  

Trade-Based Money Laundering poses major risks as complex global trade routes, fluctuating pricing, and multi-jurisdictional shipping facilitate disguising illegal funds. The sector's vulnerabilities intensify this challenge since fast-paced, cash-reliant operations focused on volume leave limited time for thorough due diligence. Lower-value goods, requiring less investment and drawing minimal scrutiny, are especially prone to money laundering or terrorist financing misuse.  

Third-Party Risk amplifies exposure through vast networks of subcontractors and suppliers operating across borders with varying regulatory enforcement. This limited visibility masks corruption, fraud, and hidden ownership structures. 

These risks take different forms across MENA countries.   

• Egypt's massive informal economy, reliance on cash, and key role in the Suez Canal all increase the risk of money laundering, terrorist financing, and smuggling.   
  
• Morocco, like Egypt, presents a complex collection of difficulties, including weaknesses in its banking system, frequent cross-border cash movement, and loopholes in AML compliance.    
• Lebanon has dangers related to its financial sector, a sizable refugee population, and illicit commerce driven by subsidy policies. These variables complicate oversight, increasing the danger of document fraud and counterfeiting.  
  
• In Saudi Arabia, concerns around cargo theft, smuggling, and TBML are significant, given the risk of supply chain corruption within its rapidly expanding free trade zones and high-value goods trade.    
• The UAE, as a major commercial and financial hub, is vulnerable to TBML, free zone misuse, cybercrime, and sanctions evasion. Even with a stronger legal framework, complex ownership structures and huge financial flows make compliance more difficult.  
  

Escalating Legal Liability compounds threats. Regulators are beginning to hold companies and executives accountable for oversight failures, even without involvement. Weak compliance frameworks can now result in significant penalties, asset seizures, and reputational damage, making financial crime risk a board-level concern.   

Key Drivers of Financial Crime Exposure in MENA Logistics   
  

Essential Steps for Effective AML Compliance  

Effective AML compliance rests on five pillars or essential steps that support financial crime detection in logistics.  
 

Appoint a dedicated AML compliance officer with expertise in the logistics sector.   
Ensure senior management approves and oversees the AML program.   
Conduct and update regular risk assessments targeting trade-based money laundering, third-party risk, sanctions, and instability.   

Tailor Anti-Money Laundering (AML) policies to logistics. Apply Customer Identification Programs (CIP), Know Your Customer (KYC), Know Your Business (KYB), and Enhanced Due Diligence (EDD) to high-risk entities. Set up third-party risk management and map supply chains to identify vulnerabilities in ports, free zones, and transit routes.   

Deploy AI-powered transaction monitoring to detect trade-based money laundering (TBML) red flags. Integrate blockchain for secure, immutable audit trails and unified global compliance. Keep thorough records of customer data, transactions, and risk assessments.   

Deliver regular, logistics-focused AML training covering red flags like cash-heavy supply chains and inconsistent shipping documents. Promote a compliance culture via scenario-based learning and ongoing updates. Perform annual independent AML audits and control testing, increasing frequency for high-risk activities.  

Establish secure cloud-based information sharing with supply chain partners. Collaborate with peers, regulators, and FIUs (Financial Intelligence Units) on typologies and best practices. Continuously update risk assessments and adjust controls for new threats and regulations.   

Adapting AML Frameworks to MENA Logistics Realities  

While the core pillars of AML compliance remain constant, firms in the Middle East and North Africa must adapt to regional realities. Fragmented regulations require FATF watchlist alignment and tailored controls in jurisdictions like the UAE, Saudi Arabia, Egypt and Morocco. Geopolitical risks demand enhanced due diligence for sanctions evasion and dual-use goods in high-risk trade corridors.   

Specialised monitoring is essential in free zones such as Dubai, Jeddah, and Casablanca, where the risk of trade-based money laundering (TBML) is elevated. To address this, blockchain technology can help close infrastructure gaps and strengthen TBML controls across ports and free zones. 

In parallel, aligning with the Global Logistics Emissions Council (GLEC) Framework v3.0 also supports emissions tracking and environmental, social, and governance (ESG) compliance in green logistics.  

How Cedar Rose Supports AML Success in Logistics   

Cedar Rose helps logistics firms meet AML obligations through a robust mix of data, technology and expertise.   
  
Our global database of millions of companies and beneficial owners strengthens KYC, KYB, and due diligence across complex, cross-border operations. Moreover, our CRiS Intelligence platform simplifies risk profiling and monitoring, while our CR Comply tool provides real-time screening and automated alerts to flag potential threats.   

Whether operating in free zones, ports, or trade corridors, logistics providers gain the visibility and control needed to reduce financial crime exposure and remain compliant.  

Get in touch to see how we can support your AML goals.   

Sources 

1. https://ripjar.com/blog/aml-regulations-in-the-middle-east-how-to-comply/
2. https://www.moodys.com/web/en/us/kyc/resources/insights/fatf-announces-decision-remove-united-arab-emirates-grey-list.html
3. https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html
4. https://gfintegrity.org/wp-content/uploads/2022/10/TBFC-in-MENA-Report-English.pdf
5. https://www.uaefiu.gov.ae/en/more/knowledge-centre/publications/trends-typology-reports/strategic-analysis-report-on-trade-based-money-laundering-tbml/
6. https://vinciworks.com/blog/what-are-the-highest-and-lowest-risk-countries-in-the-middle-east-and-north-africa-for-money-laundering/
7. https://www.tookitaki.com/compliance-hub/key-strategies-for-effective-anti-money-laundering-compliance
8. https://www.silenteight.com/blog/2025-trends-in-aml-and-financial-crime-compliance-a-data-centric-perspective-and-deep-dive-into-transaction-monitoring