The UAE has rapidly strengthened its Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) framework in recent years, positioning itself as one of the most closely regulated jurisdictions in the region. With higher global expectations from FATF and increasing cross-border financial risks, businesses in the UAE must understand the key AML/CFT laws and compliance duties to avoid penalties and maintain operational integrity.

This guide provides a complete overview of the UAE’s AML/CFT landscape, summarizing major regulations, supervisory authorities, and the practical steps companies must follow. Swenta, as a professional audit and accounting firm, supports businesses across sectors in meeting these evolving requirements.

Why AML/CFT Matters: Understanding Vulnerabilities in Key UAE Sectors

Some industries—especially real estate, corporate services, precious metals, and legal services—face higher exposure to money laundering abuse. Among these, real estate remains a major target for financial crime due to its structure, value, and global investment demand.

Why Real Estate Is Targeted by Criminals

Criminals prefer real estate because:

1. High-Value Transactions

Large amounts of illicit money can be moved through one deal, with minimal trace.

2. Historically Lower Oversight Than Banking

Complex deals, private arrangements, and flexible ownership structures create loopholes.

3. Hidden Beneficial Ownership

Shell companies, proxies, and intermediaries help disguise the true owner of funds.

4. Difficult-to-Seize Assets

Once illegal funds are converted into property, authorities often face legal and practical barriers in tracing or recovering them.

These risks not only distort market pricing but also undermine economic systems and community stability.

Core Principle of AML/CFT: The Risk-Based Approach (RBA)

The UAE follows FATF-recommended methodologies, especially the Risk-Based Approach. RBA requires businesses to allocate resources according to the level of risk they identify.

Under RBA:

• Higher-risk clients = enhanced due diligence

• Complex transactions = deeper verification

• Low-risk cases = simplified checks

This protects the financial system without overburdening low-risk businesses.

AML consultants in Dubai help companies design and implement RBA frameworks tailored to their operations.

The UAE’s Key AML/CFT Laws & Regulations

Below is an overview of the essential legislation shaping AML/CFT compliance in the UAE.

1. Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism

This is the UAE’s primary AML law. It:

• Defines money laundering and terrorism financing crimes

• Establishes penalties (including fines and imprisonment)

• Identifies supervised sectors (financial institutions & DNFBPs)

• Sets requirements for reporting suspicious transactions

• Mandates customer due diligence and record-keeping

2. Cabinet Decision No. 10 of 2019

This is the executive regulation of AML Law No. 20 of 2018. It provides detailed guidance on:

• CDD and EDD requirements

• Beneficial ownership obligations

• Risk assessment expectations

• Suspicious activity indicators

• Record-keeping procedures

• Penalties and enforcement mechanisms

3. goAML Reporting Requirements (FIU UAE)

All regulated businesses must register on goAML to:

• File Suspicious Transaction Reports (STRs)

• Submit Suspicious Activity Reports (SARs)

• Update company risk profiles

• Respond to FIU inquiries

Late registration or non-reporting is one of the most common causes of fines in DNFBPs.

4. Ultimate Beneficial Ownership (UBO) Regulations

The UAE mandates that every company must:

• Identify its real owners (natural person benefiting from the entity)

• Maintain accurate UBO registers

• Submit UBO information to relevant licensing authorities

Authorities are increasingly inspecting accuracy—not just existence—of UBO data.

5. DNFBP-Specific AML Requirements

Designated Non-Financial Businesses & Professions include:

• Real estate brokers

• Dealers in precious metals and stones

• Auditors and accountants

• Company service providers

• Legal professionals

They must follow the same AML rules as banks, including CDD, monitoring, reporting, and training.

6. 2023–2025 UAE National AML/CFT Strategy

The UAE’s roadmap focuses on:

• Strengthening enforcement

• Improving risk identification

• Expanding AML technology adoption

• Increasing inspections across DNFBPs

• Ensuring sector-specific compliance standards

These initiatives directly influence how businesses must structure AML programs.

Supervisory Bodies Overseeing AML/CFT in the UAE

Different regulators supervise different sectors, including:

✔ AMLD – Anti-Money Laundering and CFT Supervision Department (CBUAE)

Supervises financial institutions and leads national AML coordination.

✔ Ministry of Economy (MoE)

Supervises DNFBPs such as accountants, real estate firms, jewelers, and corporate service providers.

✔ FIU (Financial Intelligence Unit)

Handles suspicious reports and intelligence analysis.

✔ Free Zone Authorities (e.g., ADGM, DIFC)

Each free zone enforces its own AML framework aligned with FATF standards.

These authorities have increased inspections significantly since 2022—making compliance essential for all UAE entities.

Why Weak and Emerging Markets Receive Extra Regulatory Focus

Growing sectors with limited AML experience pose increased risks. Regulators monitor:

• Newly licensed firms with no compliance structure

• Businesses lacking trained AML officers

• Industries with historically weak oversight

• Regions experiencing rapid investment growth

This approach ensures that criminal networks cannot exploit new or uninformed businesses.

Practical Steps for Implementing AML Controls in Your Business

To comply with UAE’s AML regulations, companies should adopt the following steps:

1. Build Detailed Due Diligence Checklists

Cover identity verification, UBO checks, and source-of-funds procedures.

2. Use Technology for Transaction Monitoring

Software tools detect unusual patterns and automated red flags.

3. Train Employees Frequently

Training must be documented and renewed annually.

4. Establish Internal Policies for High-Risk Cases

This includes escalation procedures and enhanced due diligence.

5. Continuously Monitor Transactions

AML is not a one-time activity—it requires ongoing assessment.

6. Work With AML Advisors in the UAE

Professionals help identify gaps, prepare documentation, and ensure full regulatory alignment.

The UAE’s AML/CFT framework is one of the most comprehensive in the region, but also one of the fastest-evolving. With increased regulator inspections, deeper UBO validation, stronger reporting requirements, and heightened cross-border scrutiny, businesses cannot afford outdated compliance systems.

Swenta supports organizations across UAE in building robust, audit-ready AML frameworks that meet every regulatory expectation for 2025 and beyond.