UAE Free Zone AML Compliance Guide 2026
UAE anti-money laundering (AML) regulations apply to all UAE free zone businesses, not just financial institutions. Following the UAE’s exit from the FATF grey list in 2024, UAE AML enforcement has significantly increased. This guide covers key AML obligations for UAE free zone companies in 2026.
UAE AML Legal Framework
- Federal Decree-Law No. 20 of 2018 (AML/CFT Law): primary UAE AML legislation
- Cabinet Decision No. 10 of 2019: implementing regulations
- CBUAE: supervises banks and payment service providers
- SCA: supervises securities firms
- Free zone authorities: supervise their own entities for AML compliance
Which UAE Free Zone Businesses Have AML Obligations?
All UAE businesses have basic AML obligations. However, specific Designated Non-Financial Businesses and Professions (DNFBPs) have enhanced obligations:
- Real estate agents and brokers (transactions above AED 55,000)
- Dealers in precious metals and gems (transactions above AED 55,000)
- Lawyers, notaries, accountants, and auditors
- Company service providers (CSPs — registered agents, company formation agents)
- Virtual asset service providers (VASPs)
Key AML Compliance Requirements for DNFBPs
- Register with goAML portal (UAE Financial Intelligence Unit reporting system)
- Implement a written AML compliance policy
- Appoint a Money Laundering Reporting Officer (MLRO)
- Conduct customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk clients
- Screen customers against UAE and international sanctions lists
- File Suspicious Transaction Reports (STRs) via goAML when suspicious activity detected
- Maintain transaction records for 5+ years
Non-DNFBP Free Zone Companies
Companies that are not DNFBPs still have basic AML obligations: maintaining accurate financial records, not facilitating suspicious transactions, cooperating with government requests, and complying with UAE targeted financial sanctions. Most general trading and service businesses fall into this category with lighter compliance requirements.
Penalties for AML Non-Compliance
UAE AML penalties are among the highest in the world: fines up to AED 50 million for serious violations, business licence cancellation, and criminal prosecution of senior management. Following UAE’s grey list exit, enforcement actions have increased significantly. Non-compliant businesses risk banking relationships being terminated in addition to regulatory penalties.