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.
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:
Key AML compliance obligations for DNFBPs:
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.
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:
Businesses should evaluate customers’ low, medium, or high risks in terms of the following:
Transaction patterns should be analyzed for:
Certain jurisdictions possess higher AML risks based on:
For this reason, DNFBPs dealing in high-risk sectors are under obligation to apply enhanced controls, coupled with ongoing monitoring to avoid probable exposure.
Customer Due Diligence (CDD)
Customer Due Diligence is necessary before any business relationship is established. Standard CDD includes:
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:
Entity CDD requirements include:
EDD – Enhanced Due Diligence
Enhanced Due Diligence is applied if higher risk has been identified, such as:
EDD involves deeper verification, approval by senior management, and continuous monitoring.
The frequency and depth of regulatory inspections are on the rise. DNFBPs need to be ready for inspection at all times.
Preparation mainly includes:
DNFBPs need to be registered in the GoAML platform and report:
Failure to report suspicious activity is perhaps one of the most common triggers for penalties.
According to regulations, AML records must be maintained for a minimum of five years and include the following:
Conducting regular independent AML audits help to identify the following:
It helps to reduce enforcement risk through the availability of an audit-ready framework.
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:
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:
Technology-driven compliance
Modern technology-driven compliance tools include the following:
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:
In turn, these measures enhance operational security and reduce enforcement exposure.
UAE authorities have made it clear that AML enforcement will continue to get tougher as part of:
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:
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:
Proactive compliance is much less expensive than regulation.
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.
At Farahat & Co, we assist DNFBPs with:
Improve your AML framework with the help of our compliance specialists, ensuring no penalties in 2026.