The sector in brief
A stored value facility lets people load money onto a card, wallet or similar account and spend it later. Examples include prepaid cards, digital wallets and gift or travel cards. They are licensed by the Central Bank of the UAE and are designed to be easy to open and easy to use.
Convenience is the point, and also the risk. A card bought with cash and handed to another person, a wallet opened with minimal checks, or many wallets opened by the same group can all be used to move or hide money. The lighter the customer checks, the tighter the limits need to be.
Supervisors generally accept that different products carry different levels of risk. A closed-loop card that can only be used in one shop is not the same as an open-loop card that can withdraw cash anywhere. What they expect is that the firm has thought about this and set limits and controls to match.
Where the risk sits
Lightly verified accounts
Accounts opened with little or no identification are easier to misuse. Where a lighter process is allowed, it must come with low limits and close monitoring.
Cash loading
Loading cards with cash, repeatedly and in small amounts, can place illicit cash into the system without drawing attention.
Cards shared or sold
Cards passed from person to person, or bought in bulk by one buyer, defeat the link between the account and the user.
Cash withdrawal abroad
Open-loop cards used to withdraw cash in other countries move value across borders with little trace.
Mule use
Individuals recruited to open accounts and pass money through them are a common use of wallets and prepaid cards.
Who supervises you
Stored value facilities licensed in the UAE under the Central Bank's regime are supervised by the CBUAE. Providers operating in a financial free zone are supervised by that zone's regulator. Your licence defines what products you can issue, and the rules attached to it may set limits and customer requirements.
The supervisor decides the detailed rules for your licence category, so always read its current guidance alongside this page.
What supervisors expect
- A Compliance Officer or MLRO with authority and a clear programme approved by management.
- A product-by-product risk assessment, covering load methods, withdrawal options, limits and the markets served.
- Customer due diligence matched to the account's limits, with full checks where limits are higher or functions broader.
- Controls on how many cards one person can hold and on bulk or corporate purchases.
- Sanctions and politically exposed person screening, with documented review of matches.
- Monitoring for patterns such as repeated loads and withdrawals, quick in-and-out movement and use in several countries.
- Reports through goAML, training for staff and agents, record keeping and independent testing.
Red flags to watch
- Multiple cards or wallets opened with the same address, phone number or device.
- Frequent cash loads just below a threshold.
- Cards used for cash withdrawals in countries unrelated to the holder.
- Bulk corporate orders with no clear business purpose.
- Accounts that are loaded and emptied almost immediately.
- A customer who asks about limits and how to avoid checks.
A worked example
A bulk order for gift cards
A newly registered company places a large order for open-loop prepaid cards to be distributed as staff gifts. It has no staff list to share, asks for the cards to be delivered to a private address and wants them loaded immediately with cash. The firm should treat the order as higher risk: confirm who owns and controls the company, understand why so many cards are needed, ask how the cards will be distributed and decline or reduce the order if answers are poor. The order, the questions asked and the answers should all be recorded for the Compliance Officer.
How Adventant helps
Questions answered
Can a stored value product be issued without full customer checks?
Where the rules allow lighter checks, they usually come with lower limits and more monitoring. The detail depends on your licence and your supervisor's rules, so confirm what applies to each product.
Are gift cards treated differently from wallets?
The risk differs. A card that can only be used in one shop is generally lower risk than one that can withdraw cash anywhere. You should assess each product separately and set limits accordingly.
How should we deal with bulk purchases?
Treat them as a higher-risk case. Check who the buyer is, why the quantity is needed and how the cards will be used, and keep a record of your decision.
Do agents and distributors need training?
Yes, if they sell or load your products. They are often the first to meet the customer, so they need to know what to look for and how to report concerns.
When should we close an account?
When you cannot complete due diligence, when activity cannot be explained and you remain concerned, or when you have reported suspicion and the relationship is no longer acceptable. Take care not to tip the customer off.