UAE businesses that are classified as Designated Non-Financial Businesses and Professions (DNFBPs) under UAE AML law are subject to specific anti-money laundering compliance obligations beyond what applies to ordinary commercial companies.
What Are DNFBPs?
Designated Non-Financial Businesses and Professions subject to UAE AML Federal Decree Law No. 20 of 2018 include: real estate agents and developers, dealers in precious metals and stones, lawyers and notaries, accountants and auditors, company and trust service providers, and dealers in high-value goods (above AED 55,000 per transaction).
Key AML Obligations for DNFBPs
- Customer Due Diligence (CDD): Verify the identity of clients before providing services; identify UBOs
- Enhanced Due Diligence (EDD): For high-risk clients (PEPs, clients from high-risk countries)
- Record Keeping: Maintain CDD records for at least 5 years
- Suspicious Transaction Reporting (STR): Report suspicious transactions to the UAE Financial Intelligence Unit (FIU) through the goAML portal
- AML Compliance Program: Appoint a Compliance Officer, maintain AML policies, conduct staff training
Registration with the UAE FIU
All DNFBPs must register on the goAML portal (goaml.ae) operated by the UAE Central Bank’s Financial Intelligence Unit. Non-registration is a criminal offence under UAE AML law. Registration is free and takes 1–3 business days.
Penalties for AML Non-Compliance
Administrative penalties: AED 50,000–1 million for failure to conduct CDD; AED 200,000–5 million for failure to report suspicious transactions. Criminal penalties: up to 10 years imprisonment and fines of AED 5–50 million for serious AML violations.