Overview
The United Nations Office on Drugs and Crime's (UNODC) 15th Congress on Crime Prevention and Criminal Justice 9, hosted in Abu Dhabi from September 26 through October 1, has revealed technology's key role in facilitating new and dangerous varieties of transnational crime as well as deep divisions in the international community's crime fighting agendas. The conference also marks the culmination of Abu Dhabi's successful drive to revive the UAE's international anti-money laundering reputation.
Congress Priorities and Emerging Threats
The nonbinding declarations, workshop communiques and NGO recommendations produced by the Crime Congress reveal the key themes and risk factors keeping justice ministers around the world up at night and filling their staffs' side-room conversations in Abu Dhabi.
The first day of the conference saw the adoption of the "Abu Dhabi Declaration," which built on the previous Kyoto Declaration adopted at the prior UNODC crime conference. The Abu Dhabi Declaration focused on the threats and opportunities posed by rapid technological development since 2021, most prominently in AI. The declaration noted that criminal groups can leverage global communications and financial networks to coordinate transnational criminal activities and circumvent law enforcement monitoring. These global connections are also facilitating a convergence of traditionally distinct crimes and enabling terrorist and criminal organizations to exploit similar financial, technological and trafficking infrastructure. The declaration singles out emerging models including "crime as a service" and "violence as a service," while calling for improved digital forensics, Dark Web monitoring and mechanisms to trace illicit financial flows.
UNODC Executive Director Monica Juma warned that the world had reached a technological "inflection point" where the sophistication of technology-enabled criminals may outstrip the ability of many nations to confront them. The declaration specifically cited the rise of multi-billion dollar "scam centers" as an emerging trend in transnational crime. The scam centers are an expression of several of the risk factors identified in the Abu Dhabi Declaration: criminals use online platforms to reach victims across jurisdictions, exploit cryptocurrency and other alternative financial infrastructures to launder proceeds, and tap into international trafficking networks to recruit workers. Juma described such centers as a global crisis whose trafficked workers have come from more than 80 nationalities.
INTERPOL's own recommendations submitted to the conference reinforced the Declaration's emphasis on interconnected crime and technology. INTERPOL warned that technology-enabled fraud deepened affected countries' preexisting trends in corruption, human trafficking and labor exploitation. Its recommendations emphasized the need for expanded international data-sharing to combat the multinational nature of these criminal networks. It also cited how cross-border cooperation between criminal home jurisdictions and target countries had repeatedly traced and seized cybercrime proceeds.
The conference's output has also reflected a broad conception of crime prevention measures, linking it to socioeconomic development, the environment, gender, youth and indigenous rights. Civil society organization Global Initiative against Transnational Organized Crime similarly argued that countries should treat non-state actors, such as private corporations, NGOs and investigative journalists, as partners in fighting organized crime.
UAE: From Grey List to Anti-Crime Coordinator
Hosting the Crime Congress is a significant reputational milestone for the UAE, recasting Abu Dhabi from a high-risk money laundering jurisdiction into a global anti-money laundering leader. Abu Dhabi's reinvention began in 2022, when the Financial Action Task Force (FATF) placed the UAE on its "grey list" of countries with AML deficiencies. The designation coincided with media reports on Russian oligarchs moving to Dubai to evade Western sanctions, conflict gold from Africa being laundered through Emirati refineries and fugitives charged with corruption and organized crime around the world living openly in the UAE.
Abu Dhabi responded with substantive AML reforms and improvements in its cooperation with foreign judicial authorities. The FATF removed the UAE from the grey list in February 2024, noting that the country had complied with much of its mandated action plan. US Deputy Assistant Secretary Bedard, in his otherwise excoriating statement, praised the UAE's reforms as "the kind of action this Congress should be built on." He specifically cited the UAE's deployment of "Superintelligence-powered cybersecurity capabilities to combat cybercrime," the establishment of a dedicated narcotics enforcement agency and the extradition of Irish crime boss Daniel Kinahan earlier this year.
While the UAE has largely succeeded in reviving its institutional AML reputation, it remains threatened by the anti-crime and corruption trends that led to its FATF designation. Expanded US secondary sanctions on Iran through Operation Economic Outcast are a unique threat to the UAE, which maintained close financial ties to Iran for decades prior to the Iran War. Despite Abu Dhabi's reforms, Emirati corporate entities and financial institutions continue to fall under Western scrutiny for money laundering related to Russia, Iran, Sudan and the DRC sanctions efforts. The UAE will likely continue to devote significant resources to staying off the grey list despite these risk factors.
Divergent Visions for Cooperation
The nominal consensus behind the Abu Dhabi Declaration obscures significant disagreements over crime-fighting strategies, highlighted by dissents from the US and Iran focusing on how existing multinational institutions and vague norms are allegedly counterproductive in anti-crime cooperation.
Washington, routinely critical of the UN's sustainable development goals and related gender- and refugee-based priorities, provided the strongest pushback. US Deputy Assistant Secretary David Bedard accused the Crime Congress of abandoning effective crime fighting strategies in pursuit of softer strategies that failed to degrade transnational crime. Bedard also rejected calls for cross-border cooperation that amounted to uncompensated technology transfers. He instead cited US-sponsored militarized anti-narcotics and human trafficking campaigns in Latin America.
Iran joined the US in criticizing the Crime Conference's emphasis on allegedly vague human rights language. It also accused the international community of adhering to sanctions regimes that acted as an obstacle to cooperation on anti-corruption and asset seizures. Iran additionally noted that the Abu Dhabi Declaration's emphasis on scam centers failed to adequately define how the trend fit within existing international legal definitions around fraud and cybercrimes.
The significance of the US' and Iran's criticisms of the Abu Dhabi Declaration should be weighted differently due to the two nations' disparity in global influence. The US, given the size of its economy and central role in the global financial system, can independently drive global anti-crime priorities through diplomatic initiatives and sanctions threats. This capacity was most recently showcased with the US leading a multi-state crackdown on Southeast Asian-based scam centers. Iran, by contrast, lacks sufficient diplomatic or economic connections to shift global anti-crime norms on its own. Instead, it relies on multilateral forums like the Crime Congress to justify its cooperation (or lack thereof) with anti-crime norms.
A More Complex Compliance Environment
Anti-crime priorities established by the Crime Congress point toward compliance trends where businesses will increasingly be expected to account for risks related to digital assets, technology-enabled fraud and cross-border financial flows, requiring more sophisticated due diligence efforts. Companies are also exposed to the same organized crime and corruption risks highlighted in the Abu Dhabi Declaration, where even firms without an international presence can be targeted by transnational cybercriminal groups.
Businesses will likely continue to see the UAE as a key center for international commerce at the intersection of Africa, the Middle East, and Asia. Its demonstrated ability to reform its regulatory environment in the face of escalating transnational criminal threats and scrutiny from the international community will likely convince businesses that they will not need to worry about doing business in a suddenly grey-listed jurisdiction again.
Increasingly divergent anti-crime priorities also raise uncertainty for a multinational firm's compliance strategy. A US model that prioritizes direct confrontation with criminal groups and deemphasizes anti-corruption enforcement contrasts sharply with the EU's anti-crime strategy that is generally more in alignment with UN sustainable development initiatives.
