UAE anti-money laundering (AML) and counter-financing of terrorism (CFT) regulations (Federal Decree-Law No. 20 of 2018 and its executive regulations) apply to all UAE Designated Non-Financial Businesses and Professions (DNFBPs) and financial institutions. Here is the practical compliance checklist.
Who Is a DNFBP in UAE?
DNFBPs required to comply with UAE AML/CFT include: real estate brokers and agents (any property transaction), dealers in precious metals and stones (transactions of AED 55,000+), lawyers and legal professionals (providing certain services), accountants and auditors, and company service providers (those who form companies or provide nominee services). All UAE financial institutions (banks, exchange houses, insurance companies, investment managers) are also subject to AML/CFT laws.
AML/CFT Compliance Programme Requirements
- Appoint a Money Laundering Compliance Officer (MLCO) — a senior manager responsible for AML compliance
- Conduct annual Business Risk Assessment identifying your AML/CFT risk exposure
- Implement Customer Due Diligence (CDD) procedures for all clients
- Conduct Enhanced Due Diligence (EDD) for high-risk clients (PEPs, high-risk countries, complex ownership structures)
- Screen all clients and transactions against UAE/UN sanctions lists
- File Suspicious Transaction Reports (STRs) with the UAE Financial Intelligence Unit (goAML portal) when suspicious activity is identified
- Maintain transaction records for a minimum of 5 years
- Train all staff on AML/CFT policies and red flag identification annually
goAML Registration
All UAE DNFBPs and financial institutions must register on the goAML portal (goaml.uaefiu.gov.ae) to file STRs. goAML registration is free. Failure to register: AED 50,000 fine. Failure to file an STR when suspicious activity is identified: criminal penalties up to 5 years imprisonment.