Table of Contents

The UAE increasingly appears to be an alluring destination for corrupt politically exposed persons, transnational organized crime groups, and U.S.-sanctioned individuals seeking to invest their illegal proceeds. Moreover, a number of countries’ law enforcement agencies view the UAE as a base for some of the illicit activities carried out in their jurisdictions.1 This chapter examines the structure and capacity of the UAE’s law enforcement, its role in enabling money laundering and foreign corruption, and the challenges to international coordination. Emirati leaders appear to lack the political will and relevant training to truly partner with foreign law enforcement to tackle illicit behavior.

In addition to examining the UAE’s commitments to several key international anticorruption and anti–money laundering agreements, this chapter also looks at the inherent tension between national law enforcement priorities and policing in the individual emirates.

The Structure of UAE Law Enforcement

The government of the UAE is organized under a federal, presidential, and constitutional monarchy, with a federal criminal procedure code that was adopted in 1987. However, three of the emirates (Abu Dhabi, Dubai, and Sharjah) have their own police forces, which are considered branches of the federal Ministry of the Interior (MOI). The MOI prides itself on utilizing technology, even robot police officers, to create an innovative policing environment. The MOI also claims that crime is at an all-time low level. Some of the departments even have female police officers.2

Karen Greenaway
Karen Greenaway is an attorney at law who served more than twenty-two years in the U.S. Federal Bureau of Investigation as both a special agent and supervisory special agent.

The MOI works through partnerships with other federal and municipal institutions to enforce the various laws that apply to the country’s different jurisdictions.3 The MOI does not appear to have an investigative staff at the federal level, only executive management and administrative staff. However, the ministry’s exact structure is not clear, as there is no organizational chart that clearly delineates the MOI’s command and control authority.

The federal system has a separate public prosecution and judicial structure, but matters that are not assigned to the Federal Judiciary in accordance with the constitution are tried through local-level courts in Abu Dhabi, Dubai, and Ras Al Khaimah.4 Further complicating the UAE’s judicial processes is the combined use of sharia law, civil law, and, in Dubai—specifically as it relates to financial disputes and structures—English common law.

Further complicating the UAE’s judicial processes is the combined use of sharia law, civil law, and, in Dubai—specifically as it relates to financial disputes and structures—English common law.

The Emirati government publicly releases very little information regarding successful prosecutions of individual criminal cases, according to a detailed review of open source reporting. Every few months, the police will announce a major narcotics bust. However, unlike most foreign law enforcement websites, the various UAE websites do not appear to post information about arrests or convictions. Even the judicial system’s websites do not provide case specific details.5 In fact, these websites are particularly opaque when it comes to the day-to-day operations of the various courts. On the other hand, citizen services related to licensing, criminal history checks, traffic tickets, and safety advisories are clearly and prominently displayed on the various websites with clear self-help instructions.6

There also is little mention of white collar or fraud crimes and the prosecution of them. The MOI’s focus seems to be narcotics trafficking investigations and traditional violent crimes, and both the Abu Dhabi and Dubai police departments have separate units devoted to narcotics investigations.7 (Note that the Sharjah police department does not have this unit.)

Domestication of International Treaties and UN Resolutions

The UAE has been a signatory to a handful of international treaties, conventions, and United Nations (UN) resolutions that address transnational crime and corruption. The following is a discussion of some of the most important ones and the adoption of their provisions into Emirati legal structures.

The UAE signed the United Nations Convention Against Transnational Organized Crime (UNTOC) in 2002 and ratified the convention in 2007. This convention requires member states to provide a platform for cooperation targeting transnational criminal organizations. It also requires member states to designate money laundering by transnational criminal organizations as a criminal act and, generally, stipulates that member states establish an illicit asset seizure and forfeiture regime focused on criminal cases against transnational organized crime groups. Finally, the convention commits member states to setting up a sharing regime for forfeited assets. However, so far, the level of member state compliance with these provisions is unclear. A review mechanism to determine compliance with the UNTOC provisions was not adopted until 2018, and to date, it does not appear that any signatory state has been subject to this review.8

The UAE has also adopted the Kimberley Process Certification Scheme to ensure that diamonds from conflict zones are not sold in the country. In fact, in 2002, the UAE was one of the first signatories on the UN resolution that led to development of the scheme.9 However, this federal standard is virtually only applicable to Dubai, since the Dubai Multi Commodities Centre Authority is the only legal entry and exit point for rough diamonds in the country.10 On the other hand, gold can be imported and exported from Abu Dhabi and Sharjah as well. In 2005, Dubai established the Dubai Gold & Commodities Exchange, an electronic trading platform, giving Dubai more trading capability and capacity than the other emirates.11 Dubai also created its own gold accreditation program, the Dubai Good Delivery standard in 2014. However, there is no treaty or resolution that requires countries to coordinate on gold-smuggling investigations.

As a part of the international efforts to tackle transnational corruption and money laundering, the UN General Assembly adopted the United Nations Convention Against Corruption (UNCAC) in 2003. The UAE ratified this convention in 2006. Interestingly, the country’s State Audit Institution (SAI) is the lead agency on anticorruption, utilizing its audit functions to identify waste, fraud, and abuse at the federal government level and to provide forensic evidence for investigations and prosecutions of domestic corruption.12 In 2016, the government created an anticorruption unit in the Abu Dhabi Accountability Authority (ADAA).13 However, neither the SAI nor the ADAA are law enforcement bodies, thus limiting their effectiveness and impact. For example, UNCAC treaty obligations require the UAE to assist with asset recovery when a corrupt politically exposed person has invested illicit corruption proceeds in the country. Yet neither the SAI nor the ADAA have the authority to conduct an investigation or obtain legal process to freeze and forfeit illicit proceeds on behalf of a foreign government. Without this authority, a country seeking to recover assets stolen from its treasury through embezzlement and corruption will not have any legal method to force the return of these funds.

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) is a convention that is coordinated through the Organisation for Economic Co-operation and Development (OECD). More than eighty countries, including the UAE, have ratified the convention. BEPS came into force for most signatories at the beginning of 2019 and obligates countries to amend any tax laws that are not in compliance with existing tax treaties’ obligations. The convention also requires countries to create and enforce legislation that would prevent the abuse of existing tax treaties.14 As with UNCAC, the SAI is the lead agency tasked with bringing the UAE in line with the obligations under this convention.15 However, to date, the UAE does not appear to have committed any law enforcement resources to international coordination on personal or corporate tax evasion by non-UAE citizens who reside there.

Although the Gulf Cooperation Council (GCC) is an FATF member, the UAE has only agreed to be a member of the Middle East and North Africa Financial Action Task Force (MENAFATF), a regional FATF body. Regardless of its level of participation, a member of the FATF or one of its regional bodies agrees to comply with the “40 Recommendations on Combating Money Laundering and Financing of Terrorism and proliferation issued in 2012 by using the 2013 AML/CTF [anti–money laundering and counterterrorism finance] Methodology for assessing technical compliance with FATF recommendations and the effectiveness of AML/CTF systems.” The UAE promulgated a new AML/CTF law in late 2018 in anticipation of its 2019 FATF evaluation. The law’s stated purpose is to improve international cooperation in the enforcement of money laundering and terrorism financing.16

The enforcement of laws on human trafficking became a priority for the UAE when it criminalized the practice in 2006 and formed a National Committee to Combat Human Trafficking. There is no separate treaty or convention that commits the signatories to coordinate and cooperate on human trafficking. Instead, this coordination is mandated under the UNTOC, which has specific provisions related to the trafficking of persons and smuggling of migrants. Investigative statistics that the UAE provides to the U.S. Department of State as part of its annual Trafficking in Persons Report indicate that modern slavery also has been prosecuted under the human trafficking provisions of the legislation (though the UAE does not publish detailed statistics on trafficking-related investigations).17

Three complementary treaties form the basis for international law enforcement cooperation against narcotics and psychotropic drug trafficking networks: the Single Convention on Narcotic Drugs of 1961, amended by the 1972 protocol; the Convention on Psychotropic Substances of 1971; and the United Nations Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988. The UAE acceded to the first two in 1988 and the third in 1990. These conventions commit the signatory countries to international coordination in the interdiction of illegal narcotics and psychotropic substances. There are also provisions for the confiscation of illicit proceeds from narcotics trafficking. There is no review mechanism to ensure the compliance of the ratifying states. Instead, the United Nations Office on Drugs and Crime provides training, financial assistance, and coordination assistance to participating countries.18

Challenges and Obstacles to Coordinating With UAE Law Enforcement

Foreign law enforcement agencies face three primary challenges to cooperation with their Emirati counterparts: an opaque command and control structure, the oft-diverging interests of particular emirates and the federal monarchy, and constraints imposed by the UAE federal government that limit the scope and depth of international cooperation. For example, cooperation with Dubai authorities must be coordinated and overseen by federal officials. As counterproductive as it is, this constraint is not unusual; federal law enforcement structures in the United States—with notable exceptions like the New York City Police Department—are responsible for coordination with foreign countries’ law enforcement. However, in the case of the UAE, there is a patchwork of investigating authorities because each emirate is responsible for enforcing its own criminal laws.19 This makes it more difficult for international investigators to connect and build relationships with local partners.

In the case of the UAE, there is a patchwork of investigating authorities because each emirate is responsible for enforcing its own criminal laws.

As for the command and control structure, each emirate’s police department is organized differently. However, they typically contain two units that would be considered operational—the Criminal Investigative Department and the Narcotics Trafficking Department. Within each emirate’s Criminal Investigative Department, there are specialized Anti-Economic Crimes units.20 However, these units do not report to MOI executives in Abu Dhabi. Thus, liaison officers for foreign law enforcement who sit in the capital must rely on their MOI federal point of contact to connect them with the right unit in the individual emirates. Therefore, actual implementation of international cooperation with UAE law enforcement is constrained by the willingness and ability of the MOI point of contact to compel cooperation from the local police departments.

In addition, INTERPOL’s National Central Bureau—the local office for each INTERPOL member state—is located in Abu Dhabi. In recent years, the UAE has contributed significant funds to INTERPOL law enforcement projects that are coordinated out of the organization’s General Secretariat in Lyon, France. In 2018, Dubai hosted the annual international meeting of INTERPOL member states.21

INTERPOL projects involve multilateral coordination on transnational organized crime, cybercrime, and—more recently—international terrorism.22 While the UAE is obliged—in theory—under the terms of its participation in INTERPOL to follow the organization’s coordination standards, member states actually enjoy broad discretion in their implementation of these standards. In the past, the UAE has sent representatives of the Abu Dhabi National Central Bureau, as opposed to working-level investigators, to international coordination meetings. The absence of line investigators from these case coordination discussions severely limits the effectiveness of bilateral information sharing and joint operational discussions.

Further, in the last ten years, INTERPOL has been accused of allowing countries to submit Red Notices that are politically motivated.23 A Red Notice is essentially a request from one INTERPOL member state to another member state to detain an individual of interest until the country issuing the Red Notice provides the appropriate legal documentation justifying the detention request. Some countries require the underlying legal documentation in advance of the detention. The United States and most European Union countries go even further and insist that the request must be the result of a legitimate criminal investigation.

Recently, observers have suggested that the UAE uses the Red Notice system to pursue financial debtors who generally would not be prosecuted criminally in most jurisdictions.24 Even as late as 2019, after the 2018 INTERPOL conference, an attorney who defends clients who have had INTERPOL Red Notices issued based on political activity or financial debt—as opposed to criminal accusations—stated that the UAE and some other jurisdictions have been misusing the system to collect business and credit card debt and even funds for bounced checks from debtors who have fled the country. In a Foreign Policy article, the lawyer notes that an unidentified organization in the United Kingdom that assists foreign nationals with criminal charges brought by Emirati officials based upon financial debt were seeing as many as two cases a month in 2018.25

The UAE’s international law enforcement coordination structures include regional coordination that occurs through yet another organization, GCC-POL. This regional equivalent of INTERPOL is staffed with police investigators from each emirate. However, GCC-POL’s coordination relates solely to international terrorism issues. Overall, the UAE has a strong track record of cooperating on international terrorism and terrorism finance issues but is generally uncooperative and ineffective when it comes to other illicit activities and financial crimes.26

Overall, the UAE has a strong track record of cooperating on international terrorism and terrorism finance issues but is generally uncooperative and ineffective when it comes to other illicit activities and financial crimes.

Compounding the challenges arising from the UAE’s complicated foreign law enforcement liaison structures are the occasionally divergent political interests of the two main emirates: Abu Dhabi and Dubai. While the federal monarchy is a signatory on almost every international treaty that addresses transnational criminal activity, it is the individual emirate’s police force that sets its department’s priorities. These priorities are influenced by the economic interests of each emirate, which are often not in sync. Dubai’s economy relies heavily on promoting itself as a diamond and precious metals commodities trading and financial hub. This explains why the emirate adopted English common law to govern certain financial relationships, even though sharia law still applies to banking law in all of the emirates.27 Abu Dhabi’s economy, meanwhile, relies on government services and petroleum exports.

As a result, Dubai has had little incentive to address the problems of domestic or foreign corruption and money laundering. The emirate has made insufficient progress in addressing either corruption or money laundering threats emanating from inside or outside of the emirate. Even in Abu Dhabi, the implementation of anticorruption legislation and treaty obligations is focused on preventing federal government waste, fraud, and abuse. This prioritization has left the SIA as the primary point of contact for anticorruption coordination with foreign partners.

At the federal level—despite the UAE being a signatory on numerous conventions, treaties, and resolutions related to transnational organized crime and corruption, as well as participating in UNCAC evaluations of other signatory countries—it was not until 2018 that the UAE adopted a new AML/CTF law more closely aligned with FATF principles.28 And it was only through this law that the Emirati government created an independent Financial Intelligence Unit (FIU). Prior to 2018, the FIU was a part of—and reported to—the Central Bank. The previous incarnation of the unit had little law enforcement coordination capability, an established FATF recommendation that is assessed during the task force’s evaluations. A strong functioning FIU is essential for robust international cooperation on anti–money laundering.29

By far the most interesting provision under the 2018 AML/CTF law is that local authorities are required to cooperate with document collection, witness interrogation, and extradition of suspects in money laundering and terrorism-financing investigations. In addition, Emirati law enforcement is not able to refuse requests if the crime is under investigation in its jurisdiction, except where honoring the request would harm an ongoing investigation or prosecution. Further, an international request where the specific alleged offense is money laundering or terrorism financing can no longer be refused because the request violates the “confidentiality restrictions” of the relevant financial institutions (for example, banks) or DNFBPs (for example, attorneys, accountants, or real estate agents)—unless obtaining the specific material is expressly prohibited in Emirati legal statutes. Complicating enforcement, however, are new provisions regarding attorney-client privilege contained in the law.30

To date, it is not clear how individual emirates’ law enforcement agencies will implement the law. It is also not clear whether its passage will lead to greater cooperation between the UAE and those countries that have seen illicit financial outflows channeled into Dubai real estate investments and Emirati financial institutions.31 Since the law is still relatively new, it is too early for an FATF evaluation to determine its effectiveness.

If the MOI will not commit the resources to enforce the law and the confidentiality restrictions of banks and attorney-client privilege become barriers to international cooperation on money laundering and foreign corruption cases, it is very likely that the financial institutions and DNFBPs being used by corrupt PEPs and criminal figures to launder illicit proceeds in Dubai will continue to be protected.

Anemic Cooperation on Anti–Money Laundering

Western law enforcement faces additional challenges besides the emirates’ diverse political interests and the opaque operational linkages between UAE federal law enforcement agencies and emirate police departments. Particularly acute are the added challenges related to the enforcement of anticorruption and anti–money laundering laws, including complex financial crimes.

As stated above, overall, the UAE has a strong track record on regional and international coordination related to terrorism financing and a decent record related to narcotics trafficking and human trafficking. However, the crimes that require more significant cooperation—for example, on transnational organized crime groups operating from the former Soviet Union, international asset recovery, and anti–money laundering—do not appear to be priorities for the MOI. While it is true that the ministry’s inaction on these types of cases may be partially attributed to the UAE’s weak pre-2018 anti–money laundering laws, it also suggests a significant lack of political will.

The FATF’s 2020 evaluation report seems to bear this out. It noted that between 2013 and 2019, the UAE prosecuted ninety-two people—and convicted seventy-five—for terrorism financing. However, between 2013 and 2018, it prosecuted just fifty individuals for money laundering and convicted thirty-three. Of those prosecutions, only seventeen took place in Dubai. The report specifically noted “the low number of [money laundering] prosecutions in Dubai is particularly concerning, considering its recognized risk profile.”32 The report further noted that though some money laundering prosecutions had been linked to forgery and fraud, there was a “noticeable absence of consistent investigations and prosecutions of [money laundering] related to other high risk predicate crimes (such as drug trafficking), professional third-party [money laundering], and those involving higher risk sectors (such as money value transfer services or dealers in precious metals or stones).”33

Between 2013 and 2018, it [the UAE] prosecuted just fifty individuals for money laundering and convicted thirty-three. Of those prosecutions, only seventeen took place in Dubai.

Thus, the questions for foreign law enforcement are as follows: Does the UAE now have the wherewithal to enforce the 2018 anti–money laundering law and implement the obligations the country has under UNCAC? Furthermore, assuming Emirati authorities have the expertise, are they devoting the necessary resources to address money laundering crimes, which remain a significant concern for international law enforcement? Even in the private sector, in-depth knowledge of corruption and money laundering—particularly as it relates to illicit proceeds transiting through or destined for the Emirati financial system or the Dubai real estate sector—appears to be lacking.

This lack of awareness of money laundering risks affects other facets of the real estate market. For example—because much of the civil law governing Dubai’s banking system reflects tenets of sharia law—the typical property purchase is done in installment payments and not through a traditional mortgage (which charges interest, prohibited under sharia law).34 As a result, a corrupt politically exposed person or criminal has an incentive to pay for a property up front, including all banking fees, in order to avoid a long-term banking relationship. This limited transactional relationship does not provide a financial institution with enough data to assess, as recommended by the FATF, the long-term risk of a client who may be engaged in money laundering.

Unless the new FIU is empowered to set strong requirements for reporting suspicious financial activity—such as a thorough know-your-customer review when engaging in what will likely be a one-time transaction with a client—financial institutions will have broad discretionary authority to designate a transaction as suspicious. And, in turn, without robust activity reports, the FIU will have no financial data to provide to Emirati law enforcement. This leaves the MOI—as well as foreign law enforcement—without the critical information needed to launch money laundering or international corruption investigations.

The MOI does provide public information on internally organized and internationally led training attended by their staff. There are also examples of Emirati law enforcement inviting outside experts to provide training and expertise to local authorities.35 However, this training has not focused on international corruption and money laundering. A number of law enforcement executives from the UAE—including members of both the Abu Dhabi and Dubai police forces—have attended the U.S. Federal Bureau of Investigation’s (FBI) National Academy, a ten-week course for law enforcement officials who are expected to rise into executive positions in their home countries. It focuses on skills development and international cooperation. However, this FBI course is not tailored toward building capacity in specific areas of criminal investigation and instead focuses on cooperation related to international terrorism and cybercrime.36

As a result, without focused training and development on investigations related to money laundering, foreign corruption and bribery, and international asset recovery, Emirati law enforcement activity will be limited to the investigative assistance required under the new anti–money laundering law. So far, there is little evidence that UAE law enforcement has demonstrated cooperation in these types of investigations.

Without focused training and development on investigations related to money laundering, foreign corruption and bribery, and international asset recovery, Emirati law enforcement activity will be limited to the investigative assistance required under the new anti–money laundering law.

The UAE’s training appears to focus on building capacity in the day-to-day enforcement of violent crimes and other local threats. However, a troubling development is that Emirati authorities have been integrating intelligence surveillance training into law enforcement operations.37 In other words, the detection and prevention of crime is being aided by hidden cameras, secret enforcement operations, and the opaque collection of so-called evidence that is then used in court against criminal suspects. According to the government, this development is helping to protect the monarchy as opposed to enhancing law enforcement capacity.38 Regardless, the practice is blurring the lines between intelligence and evidence collection and has the potential to further complicate coordination between UAE and Western law enforcement agencies; the latter follow strong legal provisions that prohibit using intelligence collection methods to collect evidence in purely criminal cases.

Another complicating factor is the UAE law enforcement’s alleged use of torture during interviews with subjects. Civil society organizations continue to make allegations that Emirati law enforcement officers use torture to obtain confessions in some instances.39 Since the use of torture against potential subjects and witnesses in criminal cases is illegal in the United States, every European Union member state, and many other countries, a confession or admission obtained under torture would be inadmissible in these jurisdictions.40 The use of torture as a method to obtain evidence from witnesses or potential subjects could also invalidate any international cooperation mandated under the UAE’s anti–money laundering legislation and UNCAC provisions.


In the last several years, the UAE has taken some concrete steps to integrate into its criminal laws obligations that it has agreed to under a number of international treaties, conventions, and resolutions. International cooperation by the UAE has moved beyond the signature and ratification phases to the implementation of practical training and cooperation in the spheres of terrorism financing, narcotics trafficking, human trafficking, and cybercrime. However, there continues to be a hole in the UAE’s international cooperation efforts on money laundering and foreign corruption, as well as the smuggling of precious metals.

There continues to be a hole in the UAE’s international cooperation efforts on money laundering and foreign corruption, as well as the smuggling of precious metals.

The key to any change in this cooperation will be Emirati law enforcement’s improved capacity (particularly in Abu Dhabi and Dubai) to enforce the 2018 AML/CTF law. The international community should closely monitor the newly created FIU’s guidance to financial institutions on the filing of suspicious activity reports, as well as its cooperation with local law enforcement. Perhaps in its desire to improve perceptions of its international law enforcement cooperation, the UAE will begin implementing best practices on international money laundering investigations involving foreign corruption and bribery.


1 Bradley Hope, “Alleged 1MBD Co-Conspirators Sentenced to Prison,” Wall Street Journal, June 16, 2019,

2 “United Arab Emirates Ministry of Interior,”

3 “Our Partners,” United Arab Emirates Ministry of Interior,

4 “Structure of the Judicial System,” United Arab Emirates Government,

5 “Abu Dhabi Police GHQ,”

6 “Structure of the Judicial System.”

7 “Organizational Structure,” Dubai Police,

8 “United Nations Convention Against Transnational Organized Crime,” UN Office on Drugs and Crime,

9 “About the Kimberly Process,” Dubai Multi Commodities Centre,

10 Ibid.

11 “Buying Investment Gold in U.A.E.,” Bullion Directory,

12 “Convention Legal Treaties,” State Audit Institution (UAE),

13 Adam Vause et al., “The U.A.E.: An Anti-Corruption Update,” ExpertGuides, March 15, 2016,

14 “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting,” OECD,, accessed October 28, 2019.

15 “Convention Legal Treaties.”

16 Richard Gibbon, et al., “United Arab Emirates Issues New AML Law in Context of FATF Evaluation,” Anticorruption (blog), October 21, 2019,

17 Ismail Sebugwaawo, “Human Trafficking Cases Double in UAE, Government Toughens Action,” Khaleej Times, May 7, 2019,

18 “Treaties,” UN Office on Drugs and Crime,

19 “United Arab Emirates Ministry of Interior,”

20 “Dubai Seizes Multi-Million Dollars’ Worth of Fake Designer Goods,” Al Arabiya, July 19, 2014,

21 “Dubai Hosts Biggest Interpol Assembly,” Dubai Herald, November 20, 2018,

22 “Projects,” INTERPOL,

23 “Interpol Red Notice: Global Arrest System at Risk of Abuse,” France 24, April 5, 2019,; Amy Mackinnon, “The Scourge of the Red Notice,” Foreign Policy, December 3, 2018,

24 Mackinnon, “The Scourge of the Red Notice.”

25 Ibid.

26 Justin Vela, “GCC to Set Up Regional Police Force Based in Abu Dhabi,” National (UAE), December 9, 2014,

27 Michael Hwang, “The Courts of the Dubai International Financial Centre: A Common Law Island in a Civil Law Ocean,” Dubai International Financial Centre, November 1, 2008,

28 Richard J. Gibbon et al., “United Arab Emirates Issues New AML Law in Context of FATF Evaluation,” National Law Review, April 29, 2020,

29 FATF Country Database, Financial Action Task Force,

30 Gibbon, et al., “United Arab Emirates Issues New AML Law in Context of FATF Evaluation.”

31 Ibid.

32 “Anti-Money Laundering and Counter-Terrorist Financing Measures: United Arab Emirates Mutual Evaluation Report,” 4.

33 Ibid., 8.

34 “Sharia Law for Loans and Mortgages in the UAE,” Holborn Assets, December 23, 2014,

35 “Abu Dhabi Police GHQ,”

36 “National Academy,” U.S. Federal Bureau of Investigation,

37 Jenna McLaughlin, “Deep Pockets, Deep Cover: The UAE Is Paying Ex-CIA Officers to Build a Spy Empire in the Gulf,” Foreign Policy, December 21, 2017,

38 “United Arab Emirates Ministry of Interior,”

39 “HRC42 Written Statement: Torture in the United Arab Emirates,” Americans for Democracy & Human Rights in Bahrain, August 28, 2019,

40 “The New Tests of Admissibility of Confessions Under the Evidence Act 2011,” Lawfields Solicitors & Advocates, July 18, 2017,