AML Compliance Services in Dubai, UAE
Anti-Money Laundering (AML) Services in Dubai, UAE
Anti-Money Laundering Frameworks, Risk Assessments, and Regulatory Compliance for UAE Businesses
Anti-Money Laundering (AML) compliance is a mandatory requirement for regulated businesses in the UAE. Under Federal Decree-Law No. 20 of 2018 and related regulations, companies must implement proper AML and Counter Financing of Terrorism (CFT) frameworks to prevent financial crime and meet regulatory obligations.
At Farahat & Co, we support businesses in establishing and maintaining AML compliance frameworks aligned with UAE laws. Our services are designed to help organizations identify risks, implement controls, and meet reporting requirements set by regulatory authorities.
How We Support AML Compliance
- AML risk assessment and business risk profiling
- Development of AML policies and internal controls
- Customer Due Diligence (CDD) and KYC framework setup
- Transaction monitoring and suspicious activity reporting
- AML compliance review and gap analysis
- Assistance with regulatory reporting and documentation
- Ongoing advisory to meet evolving UAE AML regulations
Which Regulatory Bodies Govern AML Compliance in the UAE?
Central Bank of the UAE (CBUAE)
The CBUAE oversees AML compliance for banks, finance companies, exchange houses, and insurance firms. It issues directives in line with Federal Decree-Law No. 20 of 2018, conducts compliance audits, and requires all supervised entities to maintain effective, risk-based AML frameworks.
Financial Intelligence Unit (FIU)
The FIU operates under the CBUAE and is responsible for receiving, analysing, and acting on Suspicious Transaction Reports submitted by regulated entities. It cooperates with local authorities and international organisations to detect and prevent financial crime.
Ministry of Economy — DNFBP Oversight
The Ministry of Economy supervises Designated Non-Financial Businesses and Professions, including real estate agents, auditors, dealers in precious metals and stones, and company service providers. These entities must conduct AML risk assessments, apply customer due diligence, and report suspicious transactions to the FIU.
Dubai Financial Services Authority (DFSA) and Securities and Commodities Authority (SCA)
The SCA regulates AML compliance in capital markets, while the DFSA enforces AML requirements within the Dubai International Financial Centre. Both authorities promote transparency and investor confidence in the securities and investment sectors.
Executive Office of AML/CFT
Established in 2020, the Executive Office coordinates national AML and CFT policy to align the UAE with FATF standards. It oversees cooperation between domestic regulators and international counterparts in the global effort to combat money laundering and terrorist financing.
Core AML Laws and Regulations in the UAE
Federal Decree-Law No. 20 of 2018 and Amendments
Federal Decree-Law No. 20 of 2018 defines money laundering offences, compliance responsibilities, asset freezing powers, and criminal liability for regulated entities. Decree-Law No. 26 of 2021 expanded reporting duties, clarified beneficial ownership rules, and strengthened the FIU’s authority to act on financial intelligence.
Cabinet Decision No. 10 of 2019
This decision sets out the requirements for Customer Due Diligence, beneficial ownership disclosure, and Suspicious Transaction Report filing procedures. It aligns the UAE’s AML framework with FATF recommendations and supports international cooperation in combating financial crime.
Key Compliance Timeframes and Record Retention
UBO Register — must be established within 60 days of company formation and updated within 15 days of any change. Record retention — businesses must retain transaction records for a minimum of five years, or six years for DIFC and ADGM entities. STR filing — Suspicious Transaction Reports must be submitted to the FIU within 24 to 72 hours of identifying the suspicious activity.
AML Compliance Obligations for Businesses
Customer Due Diligence and Enhanced Due Diligence
Businesses must verify the identity of clients and confirm the legitimacy of beneficial ownership. Enhanced Due Diligence applies to Politically Exposed Persons and high-risk clients — requiring checks on the source of funds and ongoing transaction monitoring.
Reporting and Transaction Monitoring
Regulated entities must report suspicious activity to the FIU through the goAML portal. Key reports include the Suspicious Transaction Report, Fund Freeze Report, and Partial Name Match Report. Automated transaction monitoring systems are recommended to identify unusual customer behaviour and flag potentially suspicious activity in real time.
Beneficial Ownership Register (UBO)
All UAE companies are required to maintain a register of individuals who ultimately own or control the entity. The UBO register must be kept current and made available to regulatory authorities on request. This requirement is designed to improve transparency and prevent the misuse of corporate structures.
AML Policy, Compliance Officer, and Training
Organisations must appoint an AML Compliance Officer or Money Laundering Reporting Officer with sufficient authority and relevant expertise. Staff must receive regular AML training, and independent audits of internal controls must be conducted periodically to assess the effectiveness of the compliance programme.
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.
Who is Required to Comply with UAE AML Regulations?
AML compliance obligations apply to both financial institutions and Designated Non-Financial Businesses and Professions, including:
- 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
- Company service providers and trust service providers
All of the above are required to implement AML systems, conduct customer due diligence, report suspicious activity, and cooperate fully with UAE regulatory authorities.
Key AML Platforms and Systems in the UAE
goAML Portal The goAML platform is the FIU’s official reporting portal for Suspicious Transaction Reports, Fund Freeze Reports, and Partial Name Match Reports. All regulated entities must be registered on goAML and use it for all mandatory AML submissions.
Transaction Monitoring Systems Automated transaction monitoring tools help institutions identify unusual activity, detect suspicious transfers, and flag behavioural anomalies for review and reporting.
EOCN Sanctions Screening System The Executive Office for Control and Non-Proliferation system is the UAE’s designated platform for sanctions screening — covering UN designations, terrorism lists, and proliferation-related restrictions.
Penalties for AML Non-Compliance in the UAE
on-compliance with UAE AML regulations carries severe financial and criminal consequences:
- Administrative penalties — AED 50,000 to AED 5 million per violation
- Criminal penalties — imprisonment of up to 10 years and asset confiscation
- Regulatory sanctions — licence suspension, business closure, and public naming of non-compliant entities
Following the UAE’s removal from the FATF grey list in February 2024, regulatory authorities have significantly increased enforcement activity across all sectors. Businesses that have not yet formalised their AML frameworks face heightened scrutiny.
How Farahat & Co. Supports AML Compliance
Appointment of a Compliance Officer or MLRO
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. Farahat & Co. helps 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
Our team assists financial institutions and DNFBPs in identifying, assessing, and documenting crime risks relevant to their business — taking into account the nature of the business, its size, customer profiles, geographic exposure, products, and delivery channels. Risk assessments are documented, kept current, and made available to regulators on request.
Development of Internal Policies, Procedures, and Controls
We help businesses develop AML policies and internal controls proportionate to their size, risk profile, and regulatory obligations — with senior management approval. Implementation is monitored to ensure controls remain effective and aligned with current regulatory requirements.
Customer Due Diligence 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.
Recent UAE AML Regulatory Developments
UAE AML enforcement has intensified significantly. Key developments include:
- In June 2025, UAE authorities imposed cumulative penalties of AED 339 million across regulated sectors
- The CBUAE issued individual fines ranging from AED 3.5 million to AED 200 million for systemic AML breaches
- Trade finance, real estate, fintech, and virtual asset sectors are now subject to heightened regulatory scrutiny
The regulatory environment has shifted from policy development to active enforcement — with authorities demanding real-time transaction monitoring, full transparency, and adherence to global best practices. Businesses that have not implemented a robust AML framework face significant financial and reputational risk.
Frequently Asked Questions (FAQ’S) About AML
What is anti-money laundering?
Anti-money laundering refers to the laws, regulations, and controls that prevent criminals from disguising illegally obtained funds as legitimate income. In the UAE, the AML framework is established under Federal Decree-Law No. 20 of 2018 and requires regulated entities to identify, report, and prevent money laundering and terrorist financing.
Who must comply with AML regulations in the UAE?
AML compliance obligations apply to financial institutions — including banks, exchange houses, and insurance companies — as well as Designated Non-Financial Businesses and Professions such as auditors, accountants, law firms, real estate agents, dealers in precious metals, and company service providers.
What are DNFBPs under UAE AML law?
DNFBPs — Designated Non-Financial Businesses and Professions — are non-financial entities considered to be at higher risk of exposure to money laundering. In the UAE, DNFBPs include lawyers, accountants, auditors, real estate agents and developers, and dealers in precious metals and gemstones. They are supervised by the Ministry of Economy for AML compliance purposes.
What are the five pillars of AML compliance?
The five core pillars of AML compliance are risk assessment, Customer Due Diligence and Enhanced Due Diligence, transaction monitoring and reporting, record keeping, and staff training and internal controls. Together these form the foundation of an effective AML framework.
What is a Suspicious Transaction Report and when must it be filed?
A Suspicious Transaction Report is a formal report submitted to the UAE Financial Intelligence Unit via the goAML portal when a business identifies a transaction that may be linked to money laundering, terrorist financing, or other financial crime. STRs must be filed within 24 to 72 hours of the suspicious activity being identified.
What are the penalties for AML non-compliance in the UAE?
Penalties for AML non-compliance include administrative fines of AED 50,000 to AED 5 million per violation, criminal penalties of up to 10 years imprisonment, asset confiscation, licence suspension, and business closure. Following the UAE’s removal from the FATF grey list in 2024, enforcement activity has increased significantly across all regulated sectors.
Is the UAE considered high risk for AML purposes?
No. The UAE was removed from the FATF grey list in February 2024, reflecting significant improvements in its AML and CFT framework. The UAE is now considered to be broadly compliant with FATF standards and actively cooperates with international bodies on financial crime prevention.
What is the UBO register and who must maintain it?
The Ultimate Beneficial Ownership register is a mandatory record identifying the individuals who ultimately own or control a UAE company. All UAE companies are required to establish and maintain this register — within 60 days of formation — and update it within 15 days of any change in ownership or control.
How can Farahat & Co. assist with AML compliance?
Farahat & Co. provides comprehensive AML compliance services for financial institutions and DNFBPs across the UAE — covering risk assessments, policy development, CDD framework implementation, compliance officer appointment, staff training, goAML registration and reporting support, and ongoing advisory. Our team is approved by major UAE regulators. Contact us to discuss your AML compliance requirements.
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