The UAE has reinforced Anti-Money Laundering (AML) enforcement substantially over the past few years. With this, AML fines are rising at a great pace, inspections are becoming more extensive, and the scrutiny of Designing Non-Financial Businesses and Professions (DNFBPs) is greater than ever before.

In such a case, DNFBPs failing to comply would lead to very serious consequences, including financial penalties, license suspension, reputational damage, and criminal liability, with regulators hinting at even stricter supervision starting next year in 2026.

This article explains the key AML obligations for DNFBPs in the UAE, practical steps to strengthen compliance in 2026, and how businesses can avoid rising AML penalties through proper systems, training, and governance.

What Are the Main AML Duties and Responsibilities for DNFBPs in the UAE?

Under Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, DNFBPs are legally obliged to put effective AML controls in place. These requirements have been elaborated in the Cabinet Decision No. 10 of 2019 and are overseen by several UAE authorities.

The following are examples of entities that can be classified as DNFBPs:

Developers and real estate brokers
Dealers in precious metals and stones
Auditors, accountants and tax consultants
Lawyers and legal consultants
Company service providers

Key AML compliance obligations for DNFBPs:

Establishing written AML policies and procedures regarding AML
Implementing risk-based approach-compliant internal AML controls
Appoint a qualified AML Compliance Officer
It involves customer due diligence in advance before the onboarding of clients.
Monitoring transactions and reporting suspicious activities
Maintaining records that are accurate, which could be under regulatory review.

This is done through supervision by regulators in the UAE, such as the Ministry of Economy, in coordination with the UAE FIU (Financial Intelligence Unit). These steps also help to reinforce the UAE’s commitments in light of its monitoring under the FATF Grey List, hence making DNFBP compliance a national priority.

How Will Organizations Conduct Effective AML Risk Assessments In 2026 ?

A strong AML risk assessment is at the core of any effective compliance program. Regulators expect DNFBPs to adopt a documented, reviewed, and updated enterprise-wide risk assessment approach regularly.

The following should be assessed in an effective risk assessment:

Profiling of Client’s Risk

Businesses should evaluate customers’ low, medium, or high risks in terms of the following:

Nature of business activities
Ownership structure
Use of nominees or agents
Exposure to politically exposed persons (PEPs)

Transaction Risk Classification

Transaction patterns should be analyzed for:

Unusual sizes of transaction
High-value or cash-based transactions
Liquidity of money is high-speed movement.
Conflicts within client profiles

Geo-Spatial Risk Analysis

Certain jurisdictions possess higher AML risks based on:

Poor governance and weak regulatory frameworks
Exposures to sanctions
High levels of corruption indexes

For this reason, DNFBPs dealing in high-risk sectors are under obligation to apply enhanced controls, coupled with ongoing monitoring to avoid probable exposure.

What are the Requirements of Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)?

Customer Due Diligence (CDD)

Customer Due Diligence is necessary before any business relationship is established. Standard CDD includes:

Verification of clients’ identity with the use of valid documents
Understanding the purpose and nature of the relationship
Identifying the actual owner for corporate clients

One would need to fulfill the Know Your Customer (KYC) procedure, both as an individual and as an entity.

The requirements of CDD on an individual basis generally involve:

Emirates ID or passport
Proof of address
Source of funds information

Entity CDD requirements include:

Trade licence
Memorandum and Articles of Association
Ultimate beneficial owner information

EDD – Enhanced Due Diligence

Enhanced Due Diligence is applied if higher risk has been identified, such as:

Politically exposed persons
Clients from high-risk jurisdictions
Complex ownership structures

EDD involves deeper verification, approval by senior management, and continuous monitoring.

How Should DNFBPs Prepare for AML Inspections and Regulatory Reporting ?

The frequency and depth of regulatory inspections are on the rise. DNFBPs need to be ready for inspection at all times.

Preparation mainly includes:

Workflow of Reporting

DNFBPs need to be registered in the GoAML platform and report:

Suspicious Transaction Reports (STRs) should be promptly available.
Other obligatory reports that regulators need

Failure to report suspicious activity is perhaps one of the most common triggers for penalties.

Record-Keeping and Data Retention

According to regulations, AML records must be maintained for a minimum of five years and include the following:

Client onboarding documents
Risk assessments
Logs from transaction monitoring
Internal compliance reports

Independent Audits of AML

Conducting regular independent AML audits help to identify the following:

Compliance gaps
Poor internal controls
Weaknesses in documentation

It helps to reduce enforcement risk through the availability of an audit-ready framework.

Which Tools and Strategies Help Reduce AML Compliance Failures and Fines ?

With the increase in fines, DNFBPs need to be aware that there has to be a move away from manual processes and towards adopting compliance solutions.

AML Training and Awareness

Regular AML training can ensure that personnel will be able to:

Identify red flags
Understand reporting requirements
Apply AML policies appropriately

This training must be role-specific and refreshed each year.

AML Compliance Officer

Every DNFBP shall designate an experienced AML Compliance Officer, who shall be responsible for:

Oversight of AML framework
Regulatory communication
Internal Reporting and Escalation

Technology-driven compliance

Modern technology-driven compliance tools include the following:

Sanctions screening
High-risk jurisdiction screening
Automated transaction monitoring

Accurate and more efficient, managed AML software is utilized today by many different businesses to improve their accuracy and efficiency.

Outsourcing and Independent Support

Smaller DNFBPs often enjoy the following:

Outsourcing AML functions
This includes engaging independent auditors for AML.
Enhancing the overall compliance framework

In turn, these measures enhance operational security and reduce enforcement exposure.

Why AML Fines Are Expected to Rise in 2026 ?

UAE authorities have made it clear that AML enforcement will continue to get tougher as part of:

FATF action plan commitments
More cross-border information sharing
Improved supervisory coordination

The range of penalties extends from administrative fines to multi-million dirham sanctions, depending on the severity and recurrence of the violation.

Business entities that delay compliance improvements risk:

Increasing punishment
Licence suspension or cancellation
Long-term reputational damage

Practical Compliance Tips for DNFBPs to Avoid 2026 Penalties

This means that DNFBPs, in order to remain compliant and at the same time have low risk, should:

Review and update AML policies annually
Perform regular AML risk assessments
Improve CDD and EDD documentation.
Provide ongoing training to the staff.
Independent audit of AML
Use technology to enhance monitoring
Keep the regulators informed

Proactive compliance is much less expensive than regulation.

Conclusion

As AML fines continue to rise in the UAE, DNFBPs must treat compliance as a core business function, not an administrative task. Strong governance, proper risk management, and continuous monitoring are essential to avoid 2026 penalties.

Businesses that invest early in robust AML frameworks will not only meet regulatory expectations but also build credibility, protect their licences, and support sustainable growth in the UAE’s evolving regulatory environment.

Need Help with DNFBP AML Compliance in the UAE?

At Farahat & Co, we assist DNFBPs with:

AML policy development Risk assessments
GoAML registration and reporting
Independent AML audits
Regulatory inspection support

Improve your AML framework with the help of our compliance specialists, ensuring no penalties in 2026.