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AML/CFT Compliance for UAE Businesses: An Overview

The UAE has a federal framework to combat money laundering and the financing of terrorism, which has been updated in recent years. Businesses in regulated sectors, and certain designated non-financial businesses and professions, have specific duties.

Whether and how the rules apply depends on your activity and supervisor, so check the current legislation and guidance for your sector.

Who may be affected

Banks and financial institutions are supervised by their financial regulators. Other businesses, such as real estate brokers, dealers in precious metals and stones, corporate service providers and certain professionals, fall under designated supervisors, such as the relevant ministry.

Core elements of a programme

A business-wide risk assessment
Written AML/CFT policies and procedures
Customer due diligence and ongoing monitoring
Screening against sanctions and targeted financial sanctions lists
Reporting of suspicious activity to the financial intelligence unit through its reporting platform
Staff training and a designated compliance officer

Record-keeping

Records of customer identification, transactions and decisions must be retained for the period set by the rules and be accessible to supervisors.

Beneficial ownership

Knowing who ultimately owns or controls a customer is a core obligation. See beneficial ownership information and KYC documentation.

Common weaknesses

Policies that are copied and not adapted, incomplete customer files, no evidence of training and no documented risk assessment are frequently seen.

How a consultation can help

A consultation can help review policies and document sets against the applicable framework and identify gaps. Your Legal Key is not a regulator or supervisor and cannot certify compliance. See also AML compliance.

Frequently asked questions

Is AML only for banks?

No. Several non-financial sectors have obligations, depending on activity and supervisor.

Do small businesses need policies?

If covered, yes, scaled to risk and size.

Who do I report suspicious activity to?

Through the official reporting channel designated for your sector. Check the current guidance.

Related guides and services

General information only. Please read our Legal Disclaimer.