UAE Anti-Money Laundering (AML) Compliance Guide for Businesses 2026
UAE’s anti-money laundering framework is among the most stringent in the region following FATF grey-listing (2022) and subsequent removal (2024). All UAE businesses — especially those in Designated Non-Financial Businesses and Professions (DNFBPs) — must maintain robust AML compliance programmes. This guide covers UAE AML requirements for businesses in 2026.
In this guide:
UAE AML Legal Framework
- Federal Decree-Law No. 20 of 2018: UAE’s primary AML and counter-terrorism financing (CTF) law; broad application to financial institutions and DNFBPs
- Cabinet Decision No. 10 of 2019: implementing regulation for AML Law; defines obligations for reporting entities
- Ministry of Economy (MoE): primary AML regulator for DNFBPs in UAE; oversees real estate agents, gold dealers, auditors, lawyers, and company service providers
- Central Bank UAE (CBUAE): AML regulator for banks, insurance companies, exchange houses, and payment service providers
- DFSA: AML regulator for DIFC financial services firms
- FSRA: AML regulator for ADGM financial services firms
Who Are DNFBPs in UAE?
- Real estate agents and brokers: must conduct CDD (Customer Due Diligence) on buyers and sellers; register with MoE AML portal; report suspicious transactions to UAE FIU (Financial Intelligence Unit)
- Dealers in precious metals and stones: jewellery shops, gold souk traders, diamond dealers; must conduct CDD for cash transactions above AED 55,000 (USD 15,000)
- Auditors and accountants: must report suspicious activity identified during audit; cannot turn a blind eye to client AML issues
- Lawyers, notaries, and legal professionals: for specific higher-risk transactions (real estate, company formation, trust management)
- Company and trust service providers: agents who set up UAE companies for clients
UAE AML Compliance Requirements for DNFBPs
- AML Policy: written AML/CFT policy document; includes risk appetite, customer risk classification, red flags, and escalation procedures
- Compliance Officer: designated AML Compliance Officer (AMLCO); responsible for day-to-day AML compliance; must report to senior management
- Customer Due Diligence (CDD): verify customer identity before transacting; enhanced Due Diligence (EDD) for high-risk customers (PEPs, high-risk country nationals)
- Suspicious Activity Reports (SARs): file SARs via UAE FIU’s goAML portal (gofiu.ae) when suspicious activity detected; do NOT tip off the customer (“tipping off” is a criminal offence)
- MoE Registration: DNFBPs must register with MoE AML portal (aml.economy.gov.ae); registration required to operate legally
- Training: all staff must receive AML training annually; document training records
UAE AML Penalties
- Non-registration with MoE: AED 50,000-5,000,000 fine; potential business closure
- Failure to file SAR: criminal prosecution possible; AED 100,000-5,000,000 fine
- Tipping off: criminal offence; up to 5 years imprisonment
- Money laundering conviction: 7+ years imprisonment; full asset confiscation