UAE AML Initiatives: National Committee, FIU and FATF Status

UAE Initiatives to Combat Anti-Money Laundering: The Institutional Framework

Combating money laundering in the UAE is not the work of a single law or a single regulator. It runs through a network of national bodies, each with a distinct mandate, coordinated at the top by a single committee and backed by a reporting platform that channels suspicious activity data into one place. The primary legislation is Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, the Financing of Terrorism and the Financing of Illegal Organisations, effective 14 October 2025, which replaced Federal Decree-Law No. 20 of 2018. Its implementing regulation, Cabinet Resolution No. 134 of 2025, effective 14 December 2025, replaced Cabinet Decision No. 10 of 2019 and sets out the detailed procedural requirements for obligated entities.

Under this framework, any individual or entity that knowingly deals with funds derived from unlawful activity, whether by transferring, concealing, disguising, acquiring or possessing those funds, can be held liable for a money laundering offense. What has changed most since 2018 is not the underlying definition of the offense but the institutional machinery built around detecting, coordinating and reporting it. That machinery, rather than the audit-testing side of compliance, is what this article covers.

The National Committee for Combating Money Laundering and Terrorism Financing

National coordination sits with the National Committee for Combating Money Laundering and Financing of Terrorism and Financing of Illegal Organisations, generally referred to as NAMLCFTC. The Committee is chaired by the Governor of the Central Bank of the UAE (CBUAE) and brings together representatives from the CBUAE, the Ministry of Economy, the Ministry of Justice, the Public Prosecution, the Ministry of Interior, and free zone and securities regulators, so that AML/CFT policy is set in one forum rather than negotiated separately across agencies with overlapping interests.

Day-to-day coordination runs through the Committee’s Executive Office of Anti-Money Laundering and Countering the Financing of Terrorism. The Executive Office drafts national policy documents, tracks the UAE’s progress against its international commitments, and functions as the technical secretariat linking supervisory authorities, law enforcement agencies and the private sector. This replaced the earlier model, in place around 2020, of routing most AML/CFT policy through a single department inside the Ministry of Economy. The shift reflects how much broader the UAE’s compliance apparatus has become as international scrutiny of the country’s financial system increased.

The Committee also owns the UAE’s National AML/CFT Strategy and Action Plan, the document that sets multi-year priorities such as strengthening beneficial ownership transparency, improving cross-agency data sharing, and increasing the number and quality of prosecutions. Progress against that strategy is reported periodically and is one of the inputs international assessors examine when reviewing the UAE’s standing.

The Financial Intelligence Unit and goAML: Reporting Suspected Money Laundering in the UAE

The Financial Intelligence Unit (FIU), housed within the CBUAE, is the UAE’s central authority for receiving, analyzing and disseminating reports of suspicious financial activity. It sits at the operational core of the national framework: banks, exchange houses, insurers, and designated non-financial businesses and professions (DNFBPs) such as real estate agents, dealers in precious metals and stones, and corporate service providers all report to it.

Reporting itself runs through goAML, the UAE’s electronic platform for filing Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs) and other statutory disclosures. goAML replaced older, slower paper-based and email-based reporting channels with a single searchable system that lets the FIU cross-reference reports across institutions and sectors rather than reviewing each filing in isolation. Registration on goAML is mandatory for every entity within the scope of Federal Decree-Law No. 10 of 2025, and failure to register is treated as a compliance failure in its own right, separate from whether any particular transaction later turns out to involve laundering.

The FIU also issues periodic guidance and typology reports to registered entities, flagging emerging patterns, such as trade-based laundering schemes or the misuse of virtual assets, so that reporting institutions can update their internal risk indicators rather than relying solely on generic red-flag lists.

Also check: AML Compliance Services in UAE

How the UAE Assesses Money Laundering Risk and Its FATF Standing

Alongside its legal and institutional reforms, the UAE periodically conducts a National Risk Assessment (NRA), a structured exercise mapping how money laundering and terrorist financing risks are distributed across sectors, including real estate, precious metals and stones, virtual assets, trade finance, and the DNFBP sector generally. The findings feed directly into supervisory priorities: a sector flagged as higher risk in an NRA cycle typically sees more frequent inspections and stricter documentation expectations in the following period, while lower-risk sectors face a lighter, still ongoing, supervisory touch.

The NRA process, together with the broader legislative and enforcement reforms described above, was central to the UAE’s engagement with the Financial Action Task Force (FATF), the global standard-setter for AML/CFT policy. The UAE was placed under increased FATF monitoring, commonly known as the grey list, in March 2022. Over the following two years, the UAE worked through a formal FATF action plan covering areas such as beneficial ownership transparency, sanctions implementation, and the volume and quality of money laundering prosecutions and convictions. Following sustained progress on those items, the UAE was removed from the FATF grey list in February 2024.

Grey list status is not a formality. It shapes how foreign banks and counterparties assess the risk of dealing with entities based in a given country, often translating into slower correspondent banking relationships and additional due diligence on cross-border transfers. Maintaining the reforms that led to the UAE’s removal from the list, rather than treating it as a one-time exit, remains a standing policy objective for the National Committee and the bodies that report to it.

Which Authorities Supervise Anti-Money Laundering Compliance in the UAE

Supervision of AML/CFT compliance is split by sector rather than handled by one regulator for every type of business. The table below sets out which authority a given business typically answers to.

This split matters in practice because the reporting line, inspection cadence and penalty framework a business faces depend on which of these authorities its sector falls under, not on a single uniform national process.

Business Obligations Under the UAE’s Anti-Money Laundering Regime

For a business that falls within scope, whether as a financial institution or a DNFBP, engaging with this framework is not a one-time registration exercise. Each obligated entity is expected to register with the FIU on goAML, maintain a current internal risk assessment aligned with the national NRA’s sector findings, and appoint a Money Laundering Reporting Officer empowered to file reports independently of management approval. MLRO personal liability was extended under Federal Decree-Law No. 10 of 2025, which raised the stakes of the role compared with the previous law.

Beneficial ownership transparency is one of the specific areas the National Committee’s strategy has prioritized, partly because it was a recurring theme in the UAE’s FATF action plan. Businesses are expected to keep their Ultimate Beneficial Ownership declarations accurate and current, not filed once at incorporation and left unreviewed.

Also check: Declaration of Ultimate Beneficial Ownership (UBO) in UAE

Where a business suspects it has already been exposed to laundering activity, whether through a counterparty, an unusual transaction pattern, or an employee, a forensic review can establish what occurred and support the STR filed with the FIU through goAML.

Related: Forensic Audit Services | Certified Fraud Examiner

Record-keeping and staff training obligations round out the framework. Cabinet Resolution No. 134 of 2025 requires obligated entities to retain customer due diligence records and transaction data for the period set out in the implementing regulation, and to provide AML/CFT training to relevant staff on a recurring basis rather than as a one-off induction session. Supervisory authorities routinely ask for evidence of both during inspections, and a business that cannot produce training logs or historical due diligence files is treated the same as one that never carried out the work at all.

Businesses that treat these obligations as connected to a national strategy rather than as isolated paperwork tend to be better positioned when the sector they operate in is flagged in the next NRA cycle or when supervisory expectations tighten in response to the UAE’s evolving FATF commitments.

Frequently Asked Questions (FAQs)

How Farahat & Co. Can Help

Farahat & Co. supports UAE businesses in aligning with the national AML/CFT framework, including FIU and goAML registration, MLRO appointment support, UBO declaration reviews, and AML compliance program design tailored to sector-specific supervisory requirements.

Contact Farahat & Co. today to discuss your anti-money laundering compliance requirements.