SEND MONEY · GUIDE

How the UAE identifies who collects a transfer

Most countries either ban hawala or ignore it. The United Arab Emirates wrote it into a regulation, put the providers on a register and made them file every transfer.

Reviewed by the Tradergy editorial team · September 2026
In short

The United Arab Emirates brought hawala inside its regulatory perimeter rather than tolerating it outside. Under the Registered Hawala Providers Regulation, Circular No. 24/2019, a resident natural person or a juridical person may not carry on hawala activity there without a Hawala Provider Certificate from the Central Bank of the UAE. Article 4-1 requires the holder to verify the identities of remitters and beneficiaries using Emirates identity cards or passports, and to upload the details of every transfer to the Central Bank each day.

A person collecting money in the United Arab Emirates (the UAE) through a registered hawala provider is identified by document, not by account. Article 4-1 of Circular No. 24/2019 requires that provider to verify identities of remitters and beneficiaries using Emirates identity cards or passports, and the record it keeps of the person receiving has no account-number field.

Key Takeaways

  • The Registered Hawala Providers Regulation, Circular No. 24/2019, makes a Central Bank of the UAE certificate compulsory before a resident natural person or a juridical person may carry on hawala activity there.
  • Article 4-1 requires the provider to verify identities of remitters and beneficiaries using Emirates identity cards or passports.
  • The beneficiary record the Central Bank's 2021 guidance sets out runs to seven items, and an account number is not one of them.
  • A registered provider may move money and nothing else. Deposits, currency exchange, lending and virtual assets are outside the certificate.
  • Details of every transfer, remitter and beneficiary reach the Central Bank daily, and settlement account statements quarterly.

What hawala is, in the words of the regulation

Circular No. 24/2019 defines hawala activity as the arrangements for transfer and receipt of funds or equivalent value, and settlement through trade and cash. The last four words are the distinction. An ordinary transfer settles through the banking system. A hawala transfer is settled between the two providers afterwards, by trade, by cash, or by long-term net settlement, which is why the money can reach the beneficiary before anything clears.

What the beneficiary is handed is described more loosely. The Central Bank's guidance of 15 August 2021 defines a money or value transfer service as the acceptance of cash, cheques, other monetary instruments or other stores of value, and the payment of a corresponding sum in cash or other form to a beneficiary. The instruments say a sum is paid. They do not say it must be notes.

The same guidance gives the reasons the system exists: reaching beneficiaries in remote places quickly where banks do not operate, and regions with weak or non-existent banking systems. The Central Bank permits legitimate hawala activity as an important element in its support of financial inclusion.

What the Central Bank requires before somebody may do this

Article 2-1 states the rule plainly. A resident natural person or a juridical person may not carry on hawala activity in the UAE unless they hold a Hawala Provider Certificate issued by the Central Bank.

Obtaining one is an application rather than a licence contest, and the undertakings it carries are the substance of the regime. The applicant guarantees all transfers for its customers, and accepts that the Central Bank bears no responsibility whatsoever towards customer funds regardless of their value. It keeps an account with a bank operating in the country for settlement, installs alarm and closed-circuit systems, and uses authorised cash transit providers for bulk currency transfers.

Two eligibility conditions are unusual enough to name. The applicant must be legally competent, officially resident, and not of UAE nationality. And the applicant must be of good conduct, never convicted of a crime of honour or honesty, never in default to creditors, and never declared bankrupt.

The certificate runs for one year, renewable, with renewal due no later than two months before expiry.

What a registered provider may and may not do

Section 4.1 of the Central Bank's guidance of 15 August 2021 draws the boundary. It names two permitted services and three exclusions.

Permitted Not permitted
Non-commercial personal remittance transfers Taking deposits, exchanging currencies, selling and purchasing travellers cheques
Money transfers supporting commercial operations Any financial service other than money transfers, including loans, purchase of debts and virtual assets
Transactions involving or on behalf of another hawala provider inside the country

The last exclusion is nesting. It follows from Article 4-1, which requires the provider to manage its business personally and never assign that task to another person. The guidance carves out the provider's own agents in a foreign country.

What the person collecting the money has to show

The duty begins at the first dirham rather than at a reporting threshold, and the guidance requires the right level of diligence before every transaction, including for a repeat customer. It sets three levels: customer identification diligence (CID), customer due diligence (CDD) and enhanced due diligence (EDD).

Transaction What the provider must do
Natural person, 1 to 3,499 dirhams CID, unless higher risks are present, in which case CDD and EDD as well
Natural person, 3,500 to 54,999 dirhams CDD, unless higher risks are present, in which case EDD as well
Natural person, 55,000 dirhams or more CDD and EDD
Natural person from a high-risk jurisdiction, any value CDD and EDD
Politically exposed person, any value CDD and EDD
Legal person, any value CDD and EDD

The bands are written in dirhams, so which one a payment from Australia falls into depends on what it converts to. The Australian dollar to UAE dirham page carries the live figures.

Sections 3.3.2 and 3.4.1 of the guidance list what the provider records about the person receiving: the name, the Emirates identity card number or the passport number where no identity card is available, the date of birth and nationality, the address, the mobile number, the occupation, and the sender's name and country. That is seven items, and an account number is not one of them. The provider must check the details match what the sending provider supplied, and keep the record, and a copy of the identity document, for five years.

Read beside Article 4-1, which asks for identity by Emirates identity card or passport, the record describes a person rather than an account.

Does the account number rule reach this?

The published material does not settle it, and it is worth saying so rather than writing a joining clause nobody has published.

The United Arab Emirates government's banking page states the mandate flatly. From 2012 the use of the International Bank Account Number is mandatory for all electronic payments and receipts within and outside the UAE, except for making payments through a credit card. That is the only exception the page carries. It draws no distinction by destination, by amount, or by the kind of provider.

Set beside that, the Central Bank instruments describe something with no account number in it. The guidance defines the service as payment of a corresponding sum in cash or other form to a beneficiary. The beneficiary record runs to the seven items above. Article 4-1 asks for an Emirates identity card or a passport.

Neither side names the other. The government page does not mention hawala; Circular No. 24/2019 and the 2021 guidance do not mention the account number mandate. This is a claim about the record, not about the scope of the mandate. What the instruments ask a provider to write down can be read off the page; whether the account number rule reaches a payout made under them cannot, and the two questions stay separate.

How money sent from Australia reaches a recipient in the UAE

It reaches them through a counterpart rather than directly. Nothing in Circular No. 24/2019 binds a person outside the country; the regulation takes an order arriving from abroad as its starting point.

Section 3.4.1 of the 2021 guidance addresses the registered provider's partners and agents outside the UAE, and sets out what the provider must do when a transaction order reaches it from a hawala provider abroad. So the shape a sender sees is a business in their own country taking the money and the instruction, and a certificate holder in the Emirates paying it out to a named person who presents an identity document.

There is a consequence for the sending side. The guidance tells a registered provider that if an order arrives without the required sender details it cannot perform sanctions screening or judge whether the transaction is suspicious, and should require those details before releasing the funds. What the far end needs is the remitter's details in full, and the beneficiary's name as it stands on the identity document that person will present.

Where this sits beside a licensed exchange house

The registered hawala provider is not the only counter the Central Bank regulates. Exchange business is licensed under Article 65 of the Central Bank Law, through the Exchange Business Regulation, Circular No. 7/2025, in force from 26 June 2025. Its Article 8 requires minimum paid-up capital of ten, five or two million dirhams by licence category for a sole establishment or partnership, and twenty-five million dirhams for a limited liability company. Article 9 adds a bank guarantee favouring the Central Bank.

Hawala registration sets no capital figure. What it substitutes is personal: the undertakings, the individual behind the certificate, the duty to run the business in person, and the daily file. The two even point opposite ways on nationality. Under Article 7 an exchange house that is a sole establishment must be fully owned by a UAE national; a hawala applicant must not be one.

What happens outside the register

Nothing lawful. The Central Bank states that unlicensed hawala providers are not permitted to operate in the UAE, because they may service customers and jurisdictions without controls or reporting, putting their activity outside the purview of supervisors and law enforcement. Licensed financial institutions are told to detect and prevent relationships with them, and to file a suspicious transaction report where appropriate.

That is the trade the regime makes. The person collecting presents a document rather than an account. Everything around that becomes a record.

Where to look next

How international transfers work sets out the ordinary banking route this one sits beside. What a payment rail is made of takes apart the permissions any cross-border payment depends on. For live figures, see the Australian dollar to UAE dirham page.

Sources

General information about sending money to the United Arab Emirates and about the regulation of money transfer providers there. Not financial advice, and not a recommendation of any product or institution. Reviewed by the Tradergy editorial team, September 2026.

Common questions

Is hawala legal in the United Arab Emirates?

Registered hawala is legal and unregistered hawala is not. Article 2-1 of the Registered Hawala Providers Regulation, Circular No. 24/2019, effective 14 June 2019, states that a resident natural person or a juridical person may not carry on hawala activity in the country without a Hawala Provider Certificate issued by the Central Bank of the UAE.

What does the person collecting the money have to show?

An identity document. Article 4-1 of Circular No. 24/2019 requires a registered hawala provider to verify identities of remitters and beneficiaries using Emirates identity cards or passports. Sections 3.3.2 and 3.4.1 of the Central Bank's guidance of 15 August 2021 list what is recorded about the person receiving: name, identity document number, date of birth and nationality, address, mobile number, occupation, and the sender's name and country. An account number is not among them.

What is a registered hawala provider not allowed to do?

Section 4.1 of the Central Bank's guidance of 15 August 2021 lists three exclusions. A registered provider may not take deposits, exchange currencies, or sell and purchase travellers cheques. It may provide no financial service other than money transfers, which rules out loans, the purchase of debts and virtual assets. And it may not execute transactions involving or on behalf of another hawala provider inside the country.

How is this different from a licensed exchange house?

Separate regimes. Exchange business is licensed under Article 65 of the Central Bank Law through the Exchange Business Regulation, Circular No. 7/2025, whose Article 8 sets minimum paid-up capital of ten, five or two million dirhams by category for a sole establishment or partnership, and twenty-five million dirhams for a limited liability company. Article 9 adds a bank guarantee on top. Hawala registration sets no capital figure at all.

What does a registered provider report, and to whom?

Under Article 4-1 of Circular No. 24/2019 it uploads the details of all transfers, remitters and beneficiaries to the Central Bank of the UAE each day, submits statements of its settlement account quarterly, and supplies any data the Central Bank asks for. It also registers with the Financial Intelligence Unit's reporting system and reports suspicious transactions there.