AML/CFT Compliance Services

Who Counts as a DNFBP in the UAE

The UAE's AML/CFT regime applies a risk-based approach across two broad groups: licensed financial institutions, and Designated Non-Financial Businesses and Professions (DNFBPs) — a category defined by the nature of the business rather than its size. If your business falls into one of the categories below, AML/CFT registration and compliance is mandatory, regardless of whether you have ever handled a suspicious transaction.

• Real estate agents and brokers, for transactions involving the buying or selling of property
• Dealers in precious metals and stones, for any single or linked cash transaction of AED 55,000 or more
• Independent legal professionals and notaries, when preparing or executing transactions for a client involving company formation, real estate, or the management of funds
• Auditors and accountants, including tax agents and bookkeeping firms providing similar services
• Company service providers, including registered agents that form, register or manage companies, or provide a registered office, correspondence or administrative address
• Virtual asset service providers (VASPs), newly and explicitly brought into full AML/CFT scope under the 2025 law

What Changed Under the 2025 Law

Federal Decree-Law No. 10 of 2025 repealed the previous Federal Decree-Law No. 20 of 2018 and came into force on 14 October 2025, with its executive regulation — Cabinet Decision No. 134 of 2025 — following on 14 December 2025 and replacing the earlier Cabinet Decision No. 10 of 2019. The new framework is materially stricter than the one it replaced.

• Proliferation financing (the financing of weapons of mass destruction) is now a distinct criminal offense alongside money laundering and terrorism financing
• Corporate penalties for money laundering offenses rose sharply — from a AED 500,000–50 million range under the 2018 law to AED 5–100 million (or the value of the criminal property, if higher) under the 2025 law
• The Financial Intelligence Unit's (FIU) power to freeze suspected criminal funds was extended from 7 working days to 30 working days
• Ultimate beneficial owner (UBO) rules were tightened: companies must update UBO details within 15 working days of a change, bearer shares are now expressly prohibited, and nominee arrangements must be disclosed promptly
• Enhanced due diligence (EDD) requirements were made explicit for the first time, including a source-of-wealth check (not just source of funds) for higher-risk relationships

Core Compliance Obligations

• Register your business on the Ministry of Economy's goAML platform and keep your registration current
• Conduct and document a risk assessment covering money laundering, terrorism financing and proliferation financing risk, updated on an ongoing basis
• Adopt a board- or owner-approved AML/CFT policy covering customer due diligence (CDD), record-keeping and reporting procedures
• Perform CDD on every customer and identify their ultimate beneficial owner before establishing a business relationship, escalating to enhanced due diligence (EDD) for higher-risk customers, including source-of-wealth checks
• Screen customers and transactions against UN and local sanctions lists, and against politically exposed person (PEP) status
• File a Suspicious Transaction Report (STR) with the FIU without delay whenever there are reasonable grounds to suspect a transaction relates to money laundering, terrorism financing or proliferation financing
• Retain customer, transaction and supporting records for a minimum of five years from the end of the business relationship or the most recent transaction
• Appoint a compliance officer responsible for your AML/CFT program and provide regular staff training

Penalties for Non-Compliance

Non-compliance carries two layers of exposure: administrative penalties from your DNFBP supervisor (the Ministry of Economy, or the relevant free zone authority) — which can include fines, suspension of your trade licence, or referral for criminal prosecution — and criminal penalties under the federal law itself for money laundering, terrorism financing or proliferation financing offenses.

• Corporate entities: fines of AED 5 million to AED 100 million, or the value of the criminal property if higher, for money laundering offenses
• Individuals: a minimum of one year's imprisonment plus fines of up to AED 5 million for money laundering
• Providing false beneficial ownership information: imprisonment and a fine of not less than AED 20,000
• DNFBP-specific administrative sanctions for failing to register, screen customers, or file required reports — separate from and in addition to any criminal liability

How We Help

• Assess whether your business activity is a designated DNFBP category and confirm your exact obligations
• Register and maintain your profile on the Ministry of Economy's goAML platform
• Draft your risk-based AML/CFT policy, CDD/EDD procedures and record-keeping framework
• Provide or support your compliance officer function and staff AML/CFT training
• Assist with sanctions and PEP screening, ongoing monitoring, and suspicious transaction report (STR) filing when needed