23/01/2026
The “Smurfing” Mirage: Why Standard AML Thresholds Fail Against High-Velocity Algorithmic Structuring in the UAE
Executive Summary: The Middle East’s financial corridors—specifically the UAE and Saudi Arabia—are currently witnessing a tectonic shift in money laundering methodologies. The era of manual "smurfing" (breaking large cash deposits into smaller sums) is effectively dead. It has been replaced by Algorithmic Structuring, where bot-driven networks execute thousands of micro-transactions just below the reporting thresholds of Federal Decree-Law No. (20) of 2018....