May 3, 2022
The Bottom Line Up Front

As we continue to expand our dataset on property ownership in Dubai, C4ADS is collaborating with a coalition of scholars and journalists to expose the illicit networks exploiting the UAE property market.

Background #

The Dubai property market is a key haven for international kleptocrats, transnational organized crime, and a vast array of other illicit actors — from narcotics traffickers to Russian oligarchs. These networks come to the United Arab Emirates seeking the benefits of its high levels of secrecy, gaps in enforcement, and to use luxury property as a vehicle to store and launder ill-gotten gains. Since Russia’s invasion of Ukraine in early 2022, we’ve tracked Russian oligarchs moving their vessels and aircraft to Dubai, and identified at least 76 Dubai properties held by Russian and Belarusian illicit actors.

History of the Database #

In 2018, C4ADS identified 44 real estate properties held directly by sanctioned individuals, as well as another 37 held by their expanded networks — you can read about this in our landmark report, Sandcastles. We shared that data with the Organized Crime & Corruption Reporting Project (OCCRP), who conducted a series of investigations into additional illicit actors with property holdings in Dubai — read Golden Sands to learn more. We also worked alongside the Carnegie Endowment to further examine Dubai’s Role in Facilitating Corruption and Global Illicit Financial Flows. But we didn’t stop there.

Since Sandcastles was published in 2018, C4ADS has worked to collect, curate, and expand our Dubai Property Database to 833,000 Dubai property ownership records, revealing even more secrets hidden in Dubai’s luxury real estate market. Sourced from the Dubai Land Department and public utilities companies, the dataset covers a complete snapshot of Dubai real estate ownership in 2019, as well as a partial picture of ownership in 2020 and 2021. It is the most complete dataset of its kind in the public domain.

About the Coalition #

But the dataset is no good if not shared. This is why we have collaborated with a coalition of scholars and journalists from around the world to shed light on the vast illicit wealth held in Dubai’s property market.

  1. C4ADS has worked with a team of the world’s leading experts in tax justice at the University of California, Berkeley and the Norwegian University of Life Sciences (NMBU) to support a groundbreaking paper on Dubai’s role in global patterns of tax avoidance. The paper presents a comprehensive analysis of property ownership in Dubai to estimate the value of aggregate real estate owned by nationality group, and to analyze country-level patterns. Their findings provide new understanding of hidden wealth in one of the world’s largest offshore financial centers.
  2. C4ADS also provided data from our Dubai property database to a consortium of 25 journalists in 19 countries to enable their independent investigations. These examinations have exposed and revealed the overseas holdings of public officials, alleged perpetrators of international crime, sanctions evaders, and more.

Interested in collaborating with us on a project where our data may be useful? Email [email protected].

Publications We’ve Supported #

Who Owns Offshore Real Estate? Evidence From Dubai

A. Alstadsæter, G. Zucman, B. Planterose, and A. Økland | May 3, 2022

Source: Alstadsæter, A., B. Planterose, G. Zucman, and A. Økland: Who Owns Offshore Real Estate? Evidence from Dubai. EU Tax Observatory Working Paper #1, May 2022.

C4ADS has worked with a team of the world’s leading experts in tax justice at the University of California, Berkeley and the Norwegian University of Life Sciences (NMBU) to support a groundbreaking paper on Dubai’s role in global patterns of tax avoidance. The paper presents a comprehensive analysis of property ownership in Dubai to estimate the value of aggregate real estate owned by nationality group, and to analyze country-level patterns. Their findings provide new understanding of hidden wealth in one of the world’s largest offshore financial centers.

The takeaways? To clean up its domestic property market, the United Arab Emirates must improve its due diligence standards, transparency, and enforcement. More robust screening for sanctioned individuals and politically exposed persons should be combined with risk-based approaches that go beyond sanctions list. More proactive efforts by law enforcement to stop the inflows of illicit wealth can prevent future property acquisitions by corrupt officials, arms traffickers, money launderers, and other bad actors — thereby improving the UAE’s international legal and financial standing.

Investigating International Crime and Corruption in the Dubai Property Market

C4ADS also provided data from our Dubai property database to a consortium of 25 journalists in 19 countries to enable their independent investigations. These examinations have exposed and revealed the overseas holdings of public officials, alleged perpetrators of international crime, sanctions evaders, and more. See below for a list of news articles we have supported.

Dubai Uncovered – Eiliv Frich Flydal, Matthew Kupfer, Jonas Alsaker Vikan, and Fredrick Chr. Ekeseth (May 3, 2022)

Other Work We’ve Supported #

How a Playground for the Rich Could Undermine Sanctions On Oligarchs (March 9, 2022)

In the aftermath of Russia’s 2022 invasion of Ukraine, Russian political elites have sought to protect their assets from sanction and confiscation in jurisdictions like Dubai, the Maldives, and the Seychelles.

The New York Times used C4ADS’ Dubai property data to shed light on Russian and Belarusian assets in Dubai. We identified 76 properties held by these individuals in Dubai: Russian oligarchs, sanctioned members of the Duma, and allies of Putin and Lukashenka hold more than $314 million of properties in the Emirate.

Dubai’s Role in Facilitating Corruption & Global Illicit Financial Flows (July 7, 2020)

In Dubai, weak regulation, poor enforcement, and relatively high levels of secrecy and anonymity create a welcoming environment for global kleptocrats, money launderers, and other illicit entrepreneurs seeking to hide ill-gotten earnings.

C4ADS contributed to this Carnegie Endowment report, Dubai’s Role in Facilitating Corruption and Global Illicit Financial Flows.

Dubai Property: An Oasis For Nigeria’s Corrupt Political Elites (March 19, 2020)

For Nigeria’s corrupt political elites, Dubai is the perfect place to stash their ill-gotten gains and enjoy luxury real estate worth millions. But unless authorities stop turning a blind eye, the long-term costs to Nigeria’s economy and Dubai’s reputation could be high.

C4ADS contributed to this Carnegie Endowment report, Dubai Property: An Oasis for Nigeria’s Corrupt Political Elites.

Sandcastles: Tracing Sanctions Evasion Through Dubai’s Luxury Real Estate Market (June 12, 2018)

In this 2018 report, we examine seven individuals and organizations, their associated corporate networks, and their real estate holdings. We identify 44 properties worth approximately $28.2 million directly associated with sanctioned individuals, as well as 37 properties worth approximately $78.8 million within their expanded networks. Each of these people has been sanctioned by the United States (US), and many have also been designated by the European Union (EU) and EU members states. These networks are, therefore, deserving of particularly intense regulatory scrutiny. However, our research reveals that they have invested million of dollars in luxury UAE real estate while continuing to engage in illicit activity with the last few years.

Disclaimer #

C4ADS assesses this data to be credible, with the caveat that it does not constitute evidence of the same quality and standard as a property deed, a form of official documentation strictly controlled in the UAE as confidential information. The mention of any individual, company, organization, or entity in this dataset does not imply the violation of any law or international agreement.