UAE Anti-Money Laundering Compliance for Businesses

What are the AML requirements for UAE businesses?

Anti-Money Laundering (AML) compliance in the UAE is governed by Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations, along with Cabinet Decision No. 10 of 2019. These regulations apply to all "Designated Non-Financial Businesses and Professions" (DNFBPs) — which includes real estate agents, dealers in precious metals and stones, auditors, accountants, and corporate service providers. Even businesses outside the DNFBP category must comply with Ultimate Beneficial Ownership (UBO) requirements and maintain adequate records to support transaction transparency. The UAE was removed from the FATF grey list in February 2024 after demonstrating strengthened AML supervision, but compliance expectations have increased, not decreased, since the delisting. TruAccountants assists UAE businesses with UBO declarations, AML policy documentation, and transaction monitoring as part of the Growth and Scale tiers.

Who must comply with AML regulations?

Customer Due Diligence (CDD)

If your business is a DNFBP, you must perform Customer Due Diligence before establishing a business relationship or conducting a transaction above AED 55,000. CDD involves:

• Identify the customer: Obtain full name, date of birth, nationality, Emirates ID or passport number, and address. For corporate customers: trade licence, certificate of incorporation, Memorandum of Association, and list of directors and shareholders.
• Verify identity: Verify against original documents or reliable independent sources. Copies alone are insufficient — the original must be sighted.
• Identify the beneficial owner: Determine who ultimately owns or controls the customer (any natural person owning 25% or more, or exercising effective control).
• Understand the purpose of the business relationship: Document the expected nature and purpose of the relationship, the expected transaction patterns, and the source of funds.
• Ongoing monitoring: Continuously monitor the relationship to ensure transactions are consistent with the customer's known profile, business, and risk assessment.

Enhanced Due Diligence (EDD)

Enhanced measures are required for higher-risk scenarios:

• Politically Exposed Persons (PEPs) — current or former senior government officials, their family members, and close associates
• Customers from high-risk jurisdictions (as identified by FATF or the UAE's national risk assessment)
• Complex or unusually large transactions with no apparent economic purpose
• Non-face-to-face business relationships
• Correspondent banking relationships

Ultimate Beneficial Ownership (UBO)

All UAE companies — not just DNFBPs — must identify, declare, and maintain a register of their Ultimate Beneficial Owners. A UBO is any natural person who:

• Directly or indirectly owns 25% or more of the company's shares or capital
• Exercises effective control over the company through voting rights, the right to appoint or remove directors, or other means

The UBO declaration must be filed with the relevant authority:

• Mainland companies: Department of Economic Development (DED) — through the commercial licence portal
• Free zone companies: The free zone authority (DMCC, JAFZA, DAFZA, etc.)
• DIFC / ADGM entities: The respective registrar

Suspicious Transaction Reporting (STR)

If you suspect or have reasonable grounds to suspect that a transaction involves proceeds of crime, money laundering, or terrorism financing, you must file a Suspicious Transaction Report (STR) with the UAE Financial Intelligence Unit (FIU), known as goAML. Key points:

• STRs must be filed promptly — there is no specific timeframe, but delays can result in penalties
• Tipping off the customer is a criminal offence — never inform the customer that an STR has been filed
• There is no minimum transaction amount for STR filing — suspicion triggers the obligation, not the value
• Filing an STR in good faith provides legal protection to the reporter

Record keeping requirements

• All CDD documents, transaction records, and correspondence must be retained for at least 5 years after the end of the business relationship or the completion of the transaction
• Records must be sufficient to permit reconstruction of individual transactions
• Records must be available to the competent authorities upon request
• This is separate from the Corporate Tax record keeping requirement (7 years) — the longer retention period applies where both regimes overlap

AML penalties

What TruAccountants does here

• Prepare and file UBO declarations with DED or the relevant free zone authority
• Maintain the UBO register and update it when ownership changes
• Draft AML compliance policies and procedures proportionate to your business risk
• Implement customer due diligence checklists for DNFBP clients
• Support goAML registration and STR filing processes
• Maintain compliant records for the required retention periods