Anti-Money Laundering (AML)
Compliance in UAE
Introduction about AML Compliance
What is Anti-Money Laundering (AML)?
terrorism (CFT) and proliferation financing (CPF).
In the UAE, AML is governed by Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, along with Cabinet Decision No. 10 of 2019. The framework is supervised by the Executive Office for AML/CFT, the Central Bank of UAE (CBUAE), the Ministry of Economy, SCA, DFSA, and FSRA.
Scope of AML/CFT in UAE
AML/CFT obligations will apply to:
- All Financial Institutions (FIs) licensed in the UAE — onshore and in financial free zones (DIFC, ADGM).
- All DNFBPs as defined under Cabinet Decision No. 10 of 2019 (real estate, dealers in precious metals, auditors, corporate services, legal consultants).
- Virtual Asset Service Providers (VASPs) regulated by VARA in Dubai, SCA, or FSRA in ADGM.
- Non-Profit Organisations (NPOs) and charitable entities operating in the UAE.
- Government-owned entities conducting commercial activities that fall within the scope of the AML law.
Key Supervisory Authorities:
- Executive Office for AML/CFT — National coordinator, reports to the UAE Cabinet.
- Financial Intelligence Unit (FIU) — Central agency that receives and analyses STRs / SARs.
- CBUAE (Central Bank) — Supervises banks, exchange houses, insurers, finance companies.
- Ministry of Economy (MOE) — Supervises DNFBPs and maintains the goAML portal.
- SCA, DFSA, FSRA, VARA — Supervise securities firms, DIFC entities, ADGM entities, and virtual assets respectively.
AML does not apply to:
- Transactions between related entities within the same licensed group that are not part of regulated activities.]
- Employment income, government salaries, and social security payments.
- Low-risk transactions explicitly exempted under simplified Customer Due Diligence (CDD), subject to documented risk assessment.
- Purely internal bookkeeping entries with no customer-facing transactional element.
AML goAML REGISTRATION
Register on goAML and SACM immediately upon business licensing.
All DNFBPs (Designated Non-Financial Businesses & Professions) and Financial Institutions in the UAE are required to register on the goAMLportal and the SACM (Automatic Reporting System for Sanctions Lists) — without any turnover threshold. Registration must be completed as soon as the entity obtains its trade license.
Penalty for Non-Registration
- Starting AED 50,000 — up to AED 1,000,000
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Who Must Register & Comply (DNFBPs):
Real Estate Brokers & Agents
Any transaction of purchase/sale of real estate, with focus on cash transactions of AED 55,000 or more.
Dealers in Precious Metals & Stones
Single or linked cash transactions of AED 55,000 or more in gold, diamonds, and other precious commodities.
Auditors & Accountants
Independent accountants and external audit firms providing services to UAE entities.
Corporate Service Providers
Entities forming or managing companies, providing registered offices, nominee directors, or trustee services.
Lawyers, Notaries & Legal Consultants
When preparing or executing transactions related to real estate, finances, or company formation.
Financial Institutions
Banks, exchange houses, finance companies, insurers, and fintech/payment service providers regulated by CBUAE, SCA, DFSA, or FSRA.
Virtual Asset Service Providers (VASPs)
Entities dealing in crypto-assets, exchanges, and custody services, regulated by VARA, SCA, or FSRA.
The 6 Pillars of UAE AML Compliance
01
Enterprise-Wide Risk Assessment
Document a risk-based assessment of your customers, products, delivery channels, and jurisdictions. Refresh annually or on material change.
02
AML/CFT Policies & Procedures
Board-approved policy manual covering CDD, EDD, sanctions screening, record-keeping, STR/SAR reporting, and whistleblower protections.
03
MLRO Appointment
Designate a qualified Money Laundering Reporting Officer (MLRO) / Compliance Officer with direct reporting to senior management.
04
KYC & Customer Due Diligence
Identify & verify customers, UBOs (≥25% ownership), PEPs, and sanctions exposure. Apply Enhanced Due Diligence for high-risk relationships.
05
Ongoing Monitoring & Reporting
Screen transactions & customers against UN, UAE Cabinet, and OFAC sanctions lists. File STR / SAR on goAML without delay when suspicious.
06
Training & Independent Audit
Annual AML training for all staff (documented). Independent AML audit at least every 2 years to test the control framework.
Administrative Penalties for Non-Compliance
| Violation | Administrative Fine |
|---|---|
| Failure to register on the goAML portal | AED 50,000 (first time) — up to AED 1,000,000 |
| Failure to implement written AML/CFT policies & procedures | AED 50,000 – AED 200,000 |
| Failure to appoint a qualified Compliance Officer / MLRO | AED 50,000 – AED 100,000 |
| Failure to conduct Customer Due Diligence (CDD) or keep CDD records | AED 50,000 – AED 1,000,000 |
| Failure to file a Suspicious Transaction Report (STR/SAR) | AED 100,000 – AED 1,000,000 |
| Failure to conduct sanctions screening against UN/UAE lists | AED 50,000 – AED 5,000,000 |
| Dealing with a sanctioned party (targeted financial sanctions breach) | Up to AED 50,000,000 + criminal liability |
| Failure to maintain records for 5 years (minimum retention period) | AED 50,000 – AED 200,000 |
AML Compliance Packages
End-to-end AML/CFT support for DNFBPs and financial institutions in the UAE —
from goAML registration through annual audit.
AML Starter
Features:
- goAML & SACM registration
- Business Risk Assessment (BRA) template
- Basic AML Policy & Procedure manual
- UBO Declaration filing assistance
+ Upgrade Available:
with MLRO outsourcing
AML Essentials
Features:
- goAML & SACM registration
- Tailored Business Risk Assessment (BRA)
- Full AML/CFT Policy & Procedure Manual
- KYC / CDD forms & templates
- Annual AML training (1 session, up to 10 staff)
- UBO Declaration filing
+ Upgrade Available:
with outsourced MLRO
AML Enterprise
Features:
- goAML & SACM registration
- Enterprise-wide Risk Assessment
- Board-approved AML/CFT Policy Manual
- Outsourced MLRO service (annual)
- Sanctions screening system setup
- Quarterly AML training for all staff
- Independent AML audit (bi-annual)
+ Upgrade Available:
with transaction
monitoring software
Monthly MLRO
Retainer
Features:
- Dedicated outsourced MLRO
- Monthly compliance review
- STR / SAR filing assistance on goAML
- Sanctions screening support
- Regulatory correspondence handling
Quarterly
Compliance Review
Features:
- Quarterly AML health check
- KYC/CDD file review (sample)
- Policy & procedure refresh
- Training refreshers for staff
- Regulatory circular summaries
Annual AML
Audit
Features:
- Independent AML/CFT audit report
- Control effectiveness testing
- Gap analysis & remediation plan
- Management letter & board presentation
- Readiness for MOE / CBUAE inspections
UBO Declaration
& Filing
Features:
- UBO determination (≥25% threshold)
- UBO register preparation
- Filing with licensing authority
- Annual UBO refresh
Sanctions
Screening Setup
Features:
- UN, UAE & OFAC list integration
- Real-time screening tool deployment
- Alert handling workflow
- Escalation & documentation templates
AML Training &
Workshops
Features:
- Role-based AML training programs
- Red flag indicator workshops
- STR/SAR drafting masterclass
- Certificates of completion
Book for Corporate Tax Registration Services
Toll Free Number: 800 TAX24
Whatsapp Chat : +971561620954
Email us : hello@tax24.ae
Your Questions Answered, Your Experience Made Easier
Find quick answers to common questions about our technology apps, helping you get started, troubleshoot issues, and make the most of every feature.
What is the law that governs AML in the UAE?
Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and the Financing of Illegal Organisations, together with Cabinet Decision No. 10 of 2019 on its Executive Regulations.
What is goAML and who must register?
goAML is the UAE Financial Intelligence Unit’s reporting portal. Every Financial Institution and DNFBP must register on goAML to file Suspicious Transaction Reports (STR) and Suspicious Activity Reports (SAR). Registration is mandatory and free of charge.
How long must AML records be kept?
A minimum of 5 years from the date of the transaction or the end of the business relationship — or longer if required by the supervisory authority during an active investigation.
What is a DNFBP?
Designated Non-Financial Businesses and Professions — a category defined under UAE law covering real estate brokers, dealers in precious metals and stones, auditors, corporate service providers, and independent legal/accounting professionals.
What is the UBO threshold in the UAE?
An Ultimate Beneficial Owner (UBO) is any natural person who ultimately owns or controls, directly or indirectly, 25% or more of the shares/voting rights, or who otherwise exercises ultimate effective control over the entity.
What is the difference between STR and SAR?
An STR (Suspicious Transaction Report) is filed when a specific transaction is suspected of being linked to money laundering or terrorist financing. A SAR (Suspicious Activity Report) is broader and covers suspicious behaviour, even without a specific transaction.