UAE businesses — particularly those in designated non-financial businesses and professions (DNFBPs) — have specific anti-money laundering (AML) obligations under UAE law. Here is a complete guide.
UAE AML Legal Framework
UAE AML is governed by: Federal Decree-Law No. 20 of 2018 (Anti-Money Laundering and Combating the Financing of Terrorism Law), and Cabinet Decisions implementing the law. Regulator: Financial Intelligence Unit (FIU) — operated by CBUAE — is the central UAE AML authority. International framework: UAE is a member of FATF (Financial Action Task Force) — the global AML standard-setting body. The UAE has been subject to FATF scrutiny and has significantly strengthened its AML framework since 2021 to exit the FATF “grey list” (achieved in February 2024).
UAE DNFBPs: Businesses With Formal AML Obligations
Designated Non-Financial Businesses and Professions (DNFBPs) must comply with full AML obligations: real estate agents and developers, dealers in precious metals and stones (gold, diamonds), company service providers (company formation agents), trust and nominee service providers, legal professionals (certain activities), accounting and auditing professionals (certain activities), and virtual asset service providers (VARA-licensed). DNFBPs must: register with the relevant supervisory authority (Ministry of Economy for most DNFBPs), appoint a Compliance Officer, conduct Customer Due Diligence (CDD) on all clients, file Suspicious Transaction Reports (STRs) when suspicious activity is identified, and maintain records for 5 years.
All Businesses: Basic AML Obligations
Even businesses not classified as DNFBPs must: not accept cash above AED 55,000 in a single transaction (cash transaction reporting threshold), file a Currency Transaction Report if accepting above AED 55,000 in cash, and know who their customers and counterparties are (basic KYC).