Over the last decade, the UAE’s anti-money laundering (AML) framework has undergone a fundamental shift. What was once a compliance-driven exercise focused on policies and checklists has evolved into an accountability-driven regime, where regulators assess who owns AML risk, how decisions are made, and whether controls work in practice.

In 2025, UAE regulators are clear: AML compliance is no longer just about meeting minimum requirements—it is about accountability at every level of the business. This evolution has significant implications for DNFBPs, professional firms, and especially high-risk sectors such as real estate.

This article explains how AML expectations in the UAE have evolved from compliance to accountability, why real estate remains a key focus, how the risk-based approach (RBA) underpins this shift, and what businesses must do to stay aligned with regulatory expectations.

The Early AML Era: Policy-Driven Compliance

In the early stages of AML regulation, compliance largely meant:

• Having an AML policy on file

• Collecting basic KYC documents

• Conducting annual training

• Responding to regulatory requests

Success was often measured by documentation completeness, not by effectiveness. Many businesses adopted template-based policies and treated AML as a back-office function with limited senior management involvement.

While this approach met early regulatory expectations, it proved insufficient as financial crime risks grew more complex.

Why the UAE Shifted Toward Accountability

Global enforcement trends revealed a clear pattern:
Major money laundering failures occurred not because rules were missing, but because responsibility was unclear and oversight was weak.

This led to a regulatory rethink in the UAE, driven by:

• Increased cross-border financial flows

• Growth of complex corporate and real estate structures

• Global pressure to strengthen AML effectiveness

• The need to protect the UAE’s financial reputation

As a result, regulators began focusing less on what businesses say they do and more on what they actually do.

Why Real Estate Became a Priority Sector

Real estate sits at the center of this accountability shift.

Criminals prefer real estate because:

• High-value assets allow large sums to move in a single transaction

• Complex ownership structures can obscure beneficial ownership

• Historically lighter regulation than banking created vulnerabilities

• Asset conversion makes illicit funds harder to trace or recover

In several countries, unchecked illicit money in real estate has driven property prices beyond the reach of ordinary residents, reshaping cities and damaging communities. These real-world consequences explain why UAE regulators now demand strong accountability, not just compliance, from real estate professionals.

The Role of the Risk-Based Approach in This Evolution

At the heart of the shift from compliance to accountability is the risk-based approach (RBA).

Under guidance from the Financial Action Task Force (FATF), businesses are expected to:

• Identify money laundering and terrorist financing risks

• Assess their likelihood and impact

• Apply controls proportionate to those risks

Accountability arises when:

• Risks are clearly owned

• Decisions are justified and documented

• Controls are strengthened where risk is higher

Applying identical controls to all clients—regardless of risk—is now viewed as a failure of judgment, not a safe compliance choice.

What Accountability Looks Like in Practice

1. Clear Ownership of AML Risk

In 2025, regulators expect AML responsibility to be clearly defined:

• Senior management must understand and oversee AML risk

• AML officers must have authority and independence

• Escalation paths must be formal and effective

“Delegating AML to compliance” without oversight is no longer acceptable.

2. Decision-Making, Not Box-Ticking

Accountability means being able to explain:

• Why a client was classified as low or high risk

• Why enhanced due diligence was applied—or not

• Why a transaction was approved despite complexity

Regulators increasingly assess decision quality, not procedural completion.

3. Continuous Oversight and Challenge

Accountable AML frameworks include:

• Regular risk reviews

• Monitoring of ongoing relationships

• Willingness to challenge long-standing clients or profitable deals

Static client profiles signal weak accountability.

How Regulators Test Accountability During Inspections

UAE inspections in 2025 commonly include:

• Interviews with senior management

• Transaction walkthroughs

• Testing of escalation decisions

• Review of how issues were resolved

Authorities want to see who knew what, when they knew it, and what action was taken.

The Supervisory Push Toward Accountability

AML/CFT supervision in the UAE is led by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD) under the Central Bank of the UAE (CBUAE).

Since 2020, regulators have:

• Increased focus on governance and oversight

• Linked penalties to leadership failures

• Required remediation plans tied to accountability gaps

• Shifted inspections from documents to effectiveness

In 2025, AML accountability is treated as a core governance obligation.

Real Estate Professionals and Accountability Expectations

For real estate businesses, accountability is tested through:

Know Your Customer (KYC)

• Proper identification of buyers and sellers

• Verification of Ultimate Beneficial Owners (UBOs)

• Justified risk classification

Understanding the Deal

• Clear commercial rationale

• Market-aligned pricing

• Explanation for complex structures

Following the Money

• Transparent payment trails

• Scrutiny of cash, offshore, or third-party funds

Ongoing Monitoring

• Review of repeat transactions

• Escalation of changing behavior

Failing to act despite clear warning signs is now seen as an accountability failure, not a procedural gap.

Special Focus on Emerging and Weakly Regulated Markets

In developing real estate markets or sectors with limited AML maturity, accountability expectations are even higher.

Regulators pay close attention to:

• Newly licensed firms

• Rapidly growing businesses

• Relationship-driven client models

• Regions with weak historical enforcement

Strong accountability prevents these markets from becoming safe zones for illicit activity.

Practical Steps to Shift From Compliance to Accountability

To align with evolving expectations, UAE businesses should:

• Clarify AML ownership at board and management level

• Embed AML risk into business decision-making

• Strengthen documentation of judgments and approvals

• Train staff on why controls matter, not just how

• Conduct regular AML effectiveness and governance reviews

• Seek independent assessments where appropriate

Professional advisors are often engaged to benchmark accountability frameworks against current inspection trends.

Why Accountability Is Now a Strategic Advantage

An accountable AML framework:

• Reduces regulatory and penalty risk

• Improves inspection outcomes

• Builds trust with banks and counterparties

• Enhances long-term business sustainability

In 2025, regulators increasingly view accountability as the true indicator of AML strength.

The UAE’s AML landscape has clearly moved from compliance to accountability. Policies and procedures remain important—but they are only the foundation. What matters now is ownership, judgment, and action.

For real estate and other high-risk sectors, embracing accountability through a risk-based approach is no longer optional. Businesses that adapt to this evolution will not only meet regulatory expectations but also strengthen governance, reputation, and resilience in an increasingly scrutinized environment.