UAE Anti-Money Laundering (AML) Compliance for Free Zone Companies 2026
UAE Anti-Money Laundering laws (Federal Decree-Law No. 20 of 2018 and subsequent regulations) apply to all UAE-registered businesses in designated non-financial businesses and professions (DNFBPs). Free zone companies in certain activities have mandatory AML compliance obligations. This guide covers UAE AML compliance for 2026.
Which Free Zone Activities Require AML Compliance?
UAE AML regulations apply to Designated Non-Financial Businesses and Professions (DNFBPs) including:
- Real estate brokers and dealers (when conducting cash transactions above AED 55,000)
- Dealers in precious metals and precious stones
- Lawyers, notaries, and other legal professionals
- Accountants and auditors when conducting certain transactions
- Trust and company service providers (corporate formation agents)
- Virtual asset service providers (VASP) — regulated separately
UBO (Ultimate Beneficial Ownership) Register Requirements
ALL UAE companies (mainland and free zone) must maintain a UBO Register:
- UBO definition: any natural person who ultimately owns or controls 25%+ of the company, or exercises effective control
- UBO register contents: name, date of birth, nationality, UAE ID/passport number, address, nature of ownership/control
- Registration: submit UBO information to the relevant free zone authority
- Update: within 15 working days of any UBO change
- Annual confirmation: confirm UBO information is up to date annually
- Penalty for non-compliance: AED 100,000–AED 1,000,000 fine
goAML — UAE Financial Intelligence Unit Registration
DNFBPs in UAE must register on the goAML platform (UAE Financial Intelligence Unit) to file Suspicious Transaction Reports (STRs):
- goAML registration: mandatory for all DNFBPs before commencing regulated activities
- STR filing: file when a suspicious transaction is detected; no de minimis threshold
- Tipping off prohibition: do not inform the customer that an STR has been filed
AML Programme Requirements for DNFBPs
UAE DNFBP companies must maintain a written AML programme including:
- AML/CFT policies and procedures
- Designated Compliance Officer (responsible for AML)
- Customer Due Diligence (CDD) procedures: identify and verify all customers
- Enhanced Due Diligence (EDD) for high-risk customers (PEPs, higher-risk jurisdictions)
- Record keeping: minimum 5 years for CDD documents; 8 years for transaction records
- Staff AML training: annual training for all staff
FATF and UAE’s AML Standing
UAE was on FATF’s “grey list” (enhanced monitoring) from March 2022 to February 2024. UAE was removed from the grey list in February 2024 following significant reforms. UAE’s removal from the grey list improved UAE companies’ access to international banking and reduced compliance burden for UAE-headquartered businesses interacting with global financial institutions. However, UAE businesses must continue robust AML compliance — the reforms are ongoing requirements, not a one-time exercise.