The UAE has entered a new regulatory phase in 2025 as authorities strengthen supervision over Designated Non-Financial Businesses and Professions (DNFBPs). These sectors—including real estate brokers, jewellery dealers, auditors, legal firms, trust service providers, and corporate consultants—now face stricter expectations to detect and prevent financial crime.

The updated supervision rules reflect the UAE’s commitment to aligning with FATF global standards, protecting the economy, and enhancing transparency across high-risk industries. For businesses, this means stronger internal controls, mandatory reporting obligations, and closer engagement with accounting and AML specialists such as Swenta.

Why Real Estate Remains Highly Targeted Under AML Rules

Among all DNFBPs, the real estate sector sits at the top of global risk lists. Criminals continue to exploit property markets because:

1. Real Estate Enables Large Financial Movements

A single property purchase can conceal significant illicit funds.

2. Ownership Can Be Easily Hidden

Use of shell entities, offshore structures, and nominee buyers makes beneficial ownership unclear.

3. The Sector Historically Had Lower Oversight

Non-bank sectors often lacked the stringent due diligence frameworks banks have.

4. Illicit Funds Become Hard to Recover After Conversion to Assets

Once laundered into property, tracing or seizing assets becomes more complicated.

The impact extends beyond financial crime—money laundering can distort property prices, damage market stability, and undermine public trust.

Risk-Based Approach (RBA): Central to 2025 DNFBP Supervision

The updated supervision rules heavily emphasise the Risk-Based Approach, requiring DNFBPs to:

• Assess the level of ML/TF risk in their operations

• Allocate resources proportionate to identified risks

• Apply Enhanced Due Diligence (EDD) for high-risk cases

• Document every assessment and decision

• Continuously review and update business-wide risk assessments

Under FATF guidelines, every DNFBP must justify how it identifies, ranks, and mitigates risks. This is one of the biggest shifts in UAE compliance culture in 2025.

What DNFBPs Must Now Do Differently in 2025

The updated rules push DNFBPs to adopt more structured, proactive AML systems. Key expectations include:

1. Stronger KYC and Beneficial Ownership Checks

Businesses must verify:

• Identity documents

• Source of wealth and funds

• True beneficial owners

• Whether intermediaries are involved

• Any connection to high-risk jurisdictions

2. Deep Transaction Understanding

DNFBPs must assess:

• If the deal makes commercial sense

• If the price is unusually high/low

• Any complex structures or unexplained urgency

• Any mismatch between customer profile and transaction

These can signal potential money laundering.

3. Enhanced Fund Flow Monitoring

High-risk indicators include:

• Cash-heavy payments

• Offshore transfers

• Rapid movement of funds

• Layered transactions

Such cases require additional scrutiny and documentation.

4. Ongoing Monitoring of Client Relationships

The new supervision rules require:

• Periodic updates of KYC data

• Review of patterns or sudden behavioural changes

• Screening against sanctions lists

• Monitoring of unusual activity

5. Mandatory Staff Training

Regulators expect DNFBPs to:

• Train employees regularly

• Document training sessions

• Maintain internal testing or assessments

• Ensure AML officers stay updated on 2025 rules

6. Cooperation With Accounting & AML Experts

Specialists like Swenta help DNFBPs:

• Build compliant AML frameworks

• Prepare for regulatory inspections

• Conduct risk assessments

• Manage goAML reporting

• Implement internal controls

• Avoid penalties from supervisory bodies

This has become essential rather than optional.

How Supervisors Are Strengthening Enforcement in 2025

The AMLD (Anti-Money Laundering & CFT Supervision Department)—established under the CBUAE—has tightened its monitoring strategies. The 2025 framework focuses on:

✓ More frequent inspections

✓ Industry-specific guidance for DNFBPs

✓ Sector-wide risk assessments

✓ Heavy penalties for non-compliance

✓ Enhanced data collection and analytics

Supervising bodies now work to build compliance capabilities, especially in sectors where AML awareness has historically been low.

Special Attention for Emerging or Weak Markets

Some DNFBPs are newer, smaller, or less experienced—making them high-risk. Regulators are prioritizing oversight in:

• Newly established real estate agencies

• Jewellery shops with large cash dealings

• Small legal practices

• Corporate service providers

• Regions with minimal prior supervision

This ensures these sectors don’t become loopholes for criminal activity.

Practical Steps DNFBPs Should Implement Now

To prepare for the shift in 2025, DNFBPs must act immediately:

✔ Develop detailed due diligence procedures

Checklists make compliance consistent.

✔ Adopt AML technology

Automated systems flag suspicious cases faster.

✔ Train employees at every level

Teams must understand their AML responsibilities.

✔ Establish clear policies for high-risk clients

EDD must be applied wherever needed.

✔ Maintain thorough documentation for audits

Regulators expect detailed records of assessments, decisions, and controls.

✔ Seek expert support

Working with accounting & AML specialists such as Swenta ensures your systems meet 2025 DNFBP supervision standards.

The UAE’s 2025 AML supervision rules mark a significant shift in expectations for DNFBPs. The country is reinforcing its global financial integrity—and businesses must rise to meet these new standards.

By implementing strong risk assessments, improving due diligence, and leveraging expert support from firms like Swenta, DNFBPs can avoid penalties, protect their operations, and ensure long-term regulatory compliance.