Checklist Summary

Navigating Conflict-Driven Fraud Risks in the Gulf

The fraud threat facing Gulf businesses right now is not theoretical - it is active, escalating, and becoming more sophisticated by the week. Fraudsters are systematically exploiting the language of crisis: urgency, disruption, sanctions, and security. Traditional controls are necessary but no longer sufficient. This checklist gives businesses operating in or exposed to the GCC a clear, practical set of actions to take now - structured across eight critical areas.

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What's inside

• Guidance on treating all conflict-linked communications as high risk by default - including how to apply heightened scrutiny to sanctions updates, urgent payment requests, and supply chain rerouting instructions, and how to embed a "pause and verify" culture across finance, legal, and operations
• A framework for enhanced network and counterparty due diligence - covering ownership and control mapping, indirect exposure to sanctioned actors, and network-based analysis to detect hidden beneficial ownership and unusual transaction patterns
• Payment and transaction control recommendations - including dual authorisation requirements, out-of-band verification for payment amendments, and escalation thresholds for high-value or conflict-linked transactions
• Third-party and supply chain due diligence steps - with specific guidance on treating new intermediaries offering "conflict solutions" as high risk, and how to scrutinise invoices referencing fuel surcharges, security premiums, or emergency routing costs
• Brand impersonation and investor targeting guidance - covering how to monitor for unauthorised use of your brand in fake investment opportunities, forged term sheets, and spoofed domains, and how to establish rapid takedown processes
• Cyber and social engineering defence actions - including targeted staff alerts on phishing and deepfake-enabled impersonation, refresher training for high-risk functions, and incident response testing against ransomware, fraudulent payments, and reputational attacks
• Sanctions and regulatory monitoring guidance - covering how to track updates from UN, OFAC, OFSI, and Gulf regulators, and how to ensure internal teams understand their escalation obligations and red flags for circumvention
• Staff training and awareness recommendations - including scenario-based exercises, conflict-specific fraud typology training, and how to reinforce a culture where staff feel empowered to challenge suspicious requests