UAE businesses in high-risk sectors must meet strict Anti-Money Laundering obligations — from goAML registration to customer due diligence. Here is what the framework requires.
The UAE operates a comprehensive Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) framework, aligned with the Financial Action Task Force (FATF) 40 Recommendations. It places direct obligations on Designated Non-Financial Businesses and Professions (DNFBPs), supervised by the Ministry of Economy.
The Legal Framework
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing.
- Federal Decree-Law No. 20 of 2018 (as amended by Federal Decree-Law No. 26 of 2021).
- Cabinet Resolution No. 134 of 2025 (Executive Regulations).
- Cabinet Resolution No. 71 of 2024 on administrative penalties for violations.
Who Are DNFBPs?
DNFBPs are non-financial businesses that face heightened money-laundering risk because of the nature of their services or the products they deal with. In the UAE they include:
- Real estate agents and brokers.
- Dealers in precious metals and precious stones.
- Trust and company service providers.
- Independent accountants and auditors.
- Gold refineries.
Core Obligations
Every DNFBP must build and maintain a risk-based AML/CFT programme, including:
- Customer Due Diligence (CDD) and a Customer Risk Assessment (CRA).
- Identification and verification of beneficial owners.
- Screening of customers against UAE and international sanctions and terrorist lists.
- Ongoing monitoring of business relationships and transactions.
- Record-keeping in line with regulatory retention periods.
- Appointing a compliance officer and training staff.
Registration and Reporting via goAML
Businesses must register on the goAML platform — the national reporting system operated by the UAE Financial Intelligence Unit (FIU). Through goAML, entities submit Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) whenever a red flag is identified.
Common red flags
- Unusual or unexplained cash transactions.
- Complex or opaque ownership structures.
- Counterparties based in high-risk jurisdictions.
- Trade-based money laundering patterns, such as over- or under-invoicing.
Penalties
Non-compliance carries administrative penalties under Cabinet Resolution No. 71 of 2024, enforced by the Ministry of Economy and the Ministry of Justice — ranging from fines to suspension or revocation of the trade licence.
How Finrom can help
Finrom Consultancy helps DNFBPs register on goAML, build risk assessments and AML policies, screen customers and prepare for regulatory inspections. This article is a general overview and not legal advice — contact us for a tailored compliance review.
Read More