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AML Compliance Services

AML Compliance Services in the UAE

Build a defensible AML framework with UAE regulators watching more closely than ever.

Anti-Money Laundering compliance is a mandatory obligation for financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs) operating in the UAE. Farahat & Co. delivers AML compliance services that cover risk assessment, policy design, customer due diligence, and regulatory reporting, built around the UAE’s current AML/CFT legal framework. Our AML consultancy team works directly with Compliance Officers and MLROs to close gaps before regulators find them, rather than reacting after an inspection notice arrives.

  • Full framework build: risk assessments, internal policies, and controls designed around your business model, sector, and customer base.
  • Regulator-ready reporting: goAML registration, STR filing support, and sanctions screening against the UAE Consolidated List.
  • Compliance officer support: MLRO and Compliance Officer appointment, training, and ongoing advisory as regulations change.
  • Sector experience: banks, exchange houses, real estate, virtual asset service providers, and DNFBPs.

Whether you are setting up an AML programme for the first time or strengthening an existing one, our team works within your sector’s specific regulatory expectations rather than applying a generic template.

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AML Compliance

Who Regulates AML Compliance Services in the UAE?

AML oversight in the UAE is split across several regulators depending on sector, and knowing which one applies to your business shapes how your compliance programme should be built. The Central Bank of the UAE (CBUAE) supervises banks, exchange houses, finance companies, and insurers, issuing directives and conducting compliance audits across supervised entities.

The Financial Intelligence Unit (FIU), which sits under the CBUAE, receives and analyses Suspicious Transaction Reports and cooperates with local and international bodies to trace financial crime.

The Ministry of Economy oversees DNFBPs, including auditors, real estate agents, and dealers in precious metals, requiring risk assessments and due diligence from each. The Securities and Commodities Authority (SCA) and Dubai Financial Services Authority (DFSA) regulate AML compliance within capital markets and the DIFC respectively, while the Executive Office of AML/CFT coordinates national policy in line with FATF standards.

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Core AML Laws and Regulations in the UAE

Current AML Laws Behind Our AML Services UAE Work

UAE AML obligations are governed by Federal Decree-Law No. 10 of 2025, effective 14 October 2025, which repealed and replaced Federal Decree-Law No. 20 of 2018 and expanded reporting duties, beneficial ownership rules, and FIU authority. Its implementing regulation, Cabinet Resolution No. 134 of 2025, effective 14 December 2025, sets out Customer Due Diligence requirements, beneficial ownership disclosure, and Suspicious Transaction Report procedures, replacing Cabinet Decision No. 10 of 2019. MLRO personal liability has been extended under the new law, making qualified compliance officer appointment a higher priority than before, since individual accountability now sits alongside corporate liability.

Key timeframes businesses should track: the UBO register must be established within 60 days of company formation and updated within 15 days of any change. Transaction records must be retained for a minimum of five years, extending to six years for DIFC and ADGM entities. STRs must reach the FIU within 24 to 72 hours of identifying suspicious activity, and missing this window is treated as a compliance failure in its own right, separate from the underlying suspicious transaction.

Compliance Obligations of Businesses

AML Compliance Obligations Our AML Consultants Help You Meet

Customer Due Diligence and Enhanced Due Diligence

Businesses must verify client identity and confirm the legitimacy of beneficial ownership before onboarding, then keep that verification current throughout the relationship. Enhanced Due Diligence applies to politically exposed persons and other high-risk clients, requiring checks on the source of funds, senior management approval before onboarding, and ongoing transaction monitoring rather than a one-time check at account opening.

Reporting and Transaction Monitoring

Regulated entities must report suspicious activity to the FIU through the goAML portal, covering Suspicious Transaction Reports, Fund Freeze Reports, and Partial Name Match Reports. Automated transaction monitoring systems are recommended to identify unusual customer behaviour and flag potentially suspicious activity in real time, rather than relying on periodic manual review that can miss fast-moving patterns.

Beneficial Ownership Register (UBO)

All UAE companies are required to maintain a register of individuals who ultimately own or control the entity. The register must be kept current and made available to regulatory authorities on request, and gaps between actual ownership and what is on file are a common finding in regulatory inspections.

AML Policy, Compliance Officer, and Training

Organisations must appoint an AML Compliance Officer or Money Laundering Reporting Officer with sufficient authority and relevant expertise to oversee the programme. Staff must receive regular AML training tailored to their role, and independent audits of internal controls must be conducted periodically to test whether the programme works in practice, not just on paper.

Sanctions Screening

Businesses are required to screen customers and transactions against the UAE Consolidated Sanctions List through the EOCN system, which incorporates UN sanctions, terrorism lists, and proliferation-related designations. Screening should run at onboarding and on an ongoing basis, since list updates can turn an existing client into a match overnight.

Comply with AML Regulations in the UAE

Which UAE Businesses Need AML Compliance Services?

AML compliance obligations apply to both financial institutions and Designated Non-Financial Businesses and Professions across the UAE, and the list is broader than many businesses expect.

It includes banks, insurance companies, and money exchange businesses; virtual asset service providers and fintech companies; real estate developers and brokers; auditors, accountants, and law firms; dealers in precious metals and gemstones; and company service providers and trust service providers. Each of these sectors is required to implement AML systems, conduct customer due diligence, report suspicious activity, and cooperate fully with UAE regulatory authorities.

Each sector also carries a different risk profile in the eyes of regulators, and an AML programme built for a bank rarely transfers cleanly to a real estate brokerage or a precious metals dealer without meaningful adjustment to risk weighting and control design.

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Key AML Platforms and Systems

AML Platforms Our AML Compliance Services Work Within

UAE AML compliance runs through a small number of official systems, and being properly registered and active on each is treated by regulators as a baseline expectation, not an optional extra. The goAML portal is the FIU’s official reporting portal for Suspicious Transaction Reports, Fund Freeze Reports, and Partial Name Match Reports, and all regulated entities must be registered on it and use it for every mandatory AML submission.

Transaction monitoring systems help institutions identify unusual activity, detect suspicious transfers, and flag behavioural anomalies for review and reporting, ideally before a transaction settles rather than after.

The EOCN sanctions screening system, run by the Executive Office for Control and Non-Proliferation, is the UAE’s designated platform for sanctions screening, covering UN designations, terrorism lists, and proliferation-related restrictions that update frequently and require ongoing rather than one-time checks.

Fines and Enforcement Measures

Penalties for AML Non-Compliance in the UAE

Non-compliance with UAE AML regulations carries serious financial and criminal consequences, and enforcement has become considerably more active in recent years. Administrative penalties range from AED 50,000 to AED 5 million per violation, while criminal penalties can extend to imprisonment of up to 10 years alongside asset confiscation. Regulatory sanctions can also include licence suspension, business closure, and public naming of non-compliant entities, which carries its own reputational cost beyond the financial penalty.

Since the UAE’s removal from the FATF grey list in February 2024, regulatory authorities have significantly increased enforcement activity across all sectors: cumulative penalties of AED 339 million were recorded across regulated sectors in June 2025 alone, and individual CBUAE fines have ranged from AED 3.5 million to AED 200 million for systemic AML breaches. Businesses that have not yet formalised their AML frameworks face heightened scrutiny as a result.

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How Our Experts Will Help You With AML Compliance

How We Deliver AML Consultancy Services

Compliance Officer and MLRO Appointment

Every organisation subject to AML regulations must appoint a Compliance Officer or Money Laundering Reporting Officer with the authority and expertise to oversee the internal AML programme. We help businesses identify and appoint a suitably qualified compliance officer, and can provide this function directly where required. Our team is approved by major UAE regulators and experienced in compliance officer roles across regulated sectors.

AML Risk Assessment

We assist financial institutions and DNFBPs in identifying, assessing, and documenting money laundering and terrorist financing risks relevant to their business, taking into account its nature, size, customer profiles, geographic exposure, products, and delivery channels. Risk assessments are documented, kept current, and made available to regulators on request rather than produced once and left unchanged.

Policy, Procedure, and Controls Development

We help businesses develop AML policies and internal controls proportionate to their size, risk profile, and regulatory obligations, with senior management approval built into the process from the start. Implementation is monitored after rollout to ensure controls remain effective and aligned with current regulatory requirements as those requirements continue to evolve.

CDD and KYC Implementation

We assist businesses in implementing CDD and Enhanced Due Diligence processes, including customer identity verification, beneficial ownership investigation, source of funds checks for high-risk clients, systematic updating of CDD records, and obtaining senior management approval for higher-risk business relationships before they are onboarded.

UAE AML Regulations

Recent AML Enforcement Trends Shaping AML Services in UAE

UAE AML enforcement has moved decisively from policy development into active enforcement, and businesses planning their compliance approach for the year ahead need to account for that shift. Regulators now expect real-time transaction monitoring, full transparency, and adherence to global best practices, rather than accepting AML programmes that exist mainly on paper.

Trade finance, real estate, fintech, and virtual asset sectors are now subject to heightened regulatory scrutiny, reflecting where the CBUAE and Ministry of Economy have identified the greatest exposure to financial crime. Businesses that have not implemented a robust AML framework face significant financial and reputational risk as inspection activity continues to rise, and retrofitting a programme after a regulator flags gaps is considerably more disruptive than building one proactively.

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We support financial institutions and DNFBPs across the UAE with end-to-end AML compliance, from initial risk assessment through to goAML registration, reporting support, and ongoing regulatory advisory as your obligations evolve.

Our team is approved by major UAE regulators and works across banking, real estate, virtual assets, and other DNFBP sectors, building programmes sized to your actual risk exposure rather than a one-size-fits-all template.

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Important FAQs for AML Compliance Services

What is anti-money laundering compliance?

AML compliance covers the laws, controls, and reporting obligations that stop criminals from disguising illegal funds as legitimate income. In the UAE it is governed by Federal Decree-Law No. 10 of 2025 and its implementing Cabinet Resolution No. 134 of 2025.

Who needs AML compliance services in the UAE?

Financial institutions such as banks, exchange houses, and insurers, along with DNFBPs including auditors, accountants, real estate agents, law firms, and dealers in precious metals, must all maintain an AML compliance programme.

What is the role of an MLRO or Compliance Officer?

An MLRO or Compliance Officer oversees the internal AML programme, ensures policies are followed, coordinates STR filing, and reports to senior management and regulators. Personal liability for this role was extended under Federal Decree-Law No. 10 of 2025.

How long must AML records be retained in the UAE?

Transaction and customer due diligence records must be retained for a minimum of five years, extending to six years for entities regulated within the DIFC and ADGM.

What happens if a business fails to comply with UAE AML law?

Non-compliance can trigger administrative fines between AED 50,000 and AED 5 million per violation, criminal penalties of up to 10 years’ imprisonment, asset confiscation, and licence suspension or business closure.

How can Farahat & Co. support my AML compliance programme?

We provide AML risk assessments, policy and controls development, CDD and KYC implementation, Compliance Officer or MLRO appointment, and ongoing regulatory advisory for financial institutions and DNFBPs across the UAE.

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