UAE Anti-Money Laundering (AML) Compliance for Businesses Guide 2026
UAE has a robust AML (Anti-Money Laundering) and CFT (Combating Financing of Terrorism) framework following FATF (Financial Action Task Force) greylisting in 2022 and successful exit from the FATF greylist in 2024. UAE businesses, especially DNFBPs (Designated Non-Financial Businesses and Professions), have AML obligations. This guide covers UAE AML compliance for 2026.
In this guide:
UAE AML Legal Framework
- Federal Decree-Law No. 20 of 2018 on AML and Combating Financing of Terrorism: primary UAE AML law
- Cabinet Decision No. 10 of 2019: implementing regulations
- FATF membership: UAE is a FATF member; successfully exited FATF greylist in February 2024 after significant AML reforms
- Regulator: UAE Financial Intelligence Unit (FIU); Ministry of Economy (for DNFBPs); CBUAE (for banks and financial institutions)
Who Has UAE AML Obligations?
- Banks and financial institutions: highest AML requirements; CBUAE-regulated; extensive KYC, transaction monitoring, SAR (Suspicious Activity Report) filing
- DNFBPs (Designated Non-Financial Businesses and Professions): real estate agents and brokers; gold and precious metals dealers; auditors and accountants (when doing certain activities); lawyers (when handling client funds or certain transactions); company formation agents; trust and company service providers
- UAE businesses NOT typically covered by AML law: standard trading companies, service companies with no DNFBP activities; HOWEVER all UAE businesses must comply with general AML provisions (don’t facilitate money laundering)
UAE AML Requirements for DNFBPs
- Customer Due Diligence (CDD): verify customer identity before doing business; collect passport, proof of address, source of funds for large transactions
- Enhanced Due Diligence (EDD): for high-risk customers (PEPs — Politically Exposed Persons; high-risk countries; complex ownership structures); additional scrutiny required
- Suspicious Transaction Reports (STRs): must file STR with UAE FIU (via goAML system) if you suspect a transaction involves money laundering; failing to file when you should have = criminal offence
- AML policies and procedures: DNFBPs must have written AML/CFT policies; train staff; appoint an AML compliance officer; conduct risk assessments
Practical AML Steps for UAE Businesses
- Know your customer (KYC): always verify who you’re doing business with; collect ID documents; understand the purpose of the business relationship
- Suspicious activity: if a transaction pattern makes no commercial sense; customer is reluctant to provide information; large cash transactions; transactions with sanctioned jurisdictions — these are red flags; file STR if in doubt
- Sanctions screening: check your customers against UAE sanctions lists (UAEOL, UN Security Council lists); do not engage with sanctioned individuals or entities; violation is a criminal offence
- goAML registration: DNFBPs must register on UAE FIU goAML portal for STR filing; this is mandatory