AML compliance in the UAE has entered a new phase. In 2025, regulators are no longer focused only on policies, checklists, or the appointment of an AML Officer. Instead, the spotlight has shifted to accountability—specifically, who inside the company is responsible when AML controls fail.

For UAE companies, including DNFBPs and high-risk sectors like real estate, directors, partners, and finance teams are now directly accountable for the effectiveness of AML systems. This reflects a global move away from “compliance as a function” toward compliance as a leadership responsibility.

This article explains how AML accountability is distributed within UAE companies, why real estate is under enhanced scrutiny, how the risk-based approach (RBA) shapes responsibilities, and what regulators expect from senior management and operational teams in 2025.

Why AML Accountability Matters More Than Ever in 2025

UAE regulators increasingly assess AML failures as governance failures, not technical oversights. When breaches occur, authorities ask:

• Did senior management set the right tone?

• Were risks properly understood and escalated?

• Did finance teams question unusual transactions?

• Was compliance empowered or sidelined?

In many recent enforcement actions, weaknesses were traced back to lack of ownership at the top, even where written AML policies existed.

Why Real Estate Faces Heightened AML Accountability

Real estate remains one of the most closely monitored sectors under the UAE AML regime.

Criminals are drawn to property transactions because:

• High asset values enable movement of large sums in a single deal

• Complex ownership structures can obscure beneficial owners

• Lower historical regulation compared to banking increases vulnerability

• Asset conversion makes illicit funds harder to trace or seize

In several countries, unchecked illicit money in real estate has inflated prices, disrupted communities, and weakened trust in markets. These real-world consequences explain why regulators demand clear accountability across all levels of real estate businesses—not just from compliance teams.

The Risk-Based Approach and Shared Responsibility

Under the framework of the Financial Action Task Force (FATF), AML compliance must follow a risk-based approach (RBA).

This means:

• Higher-risk activities receive stronger controls

• Lower-risk transactions follow proportionate measures

• Decisions are justified and documented

Crucially, RBA is not the responsibility of one person. It requires:

• Strategic oversight by directors and partners

• Operational vigilance by finance teams

• Technical execution by compliance and AML officers

If any layer fails, the entire framework weakens.

AML Responsibilities of Directors and Board Members

In 2025, UAE regulators expect directors to play an active oversight role in AML compliance.

Key Director Responsibilities

• Approving AML policies and risk appetite

• Ensuring sufficient AML resources and authority

• Reviewing high-risk exposure reports

• Challenging management on weak controls

• Setting a strong “tone from the top”

Directors are not expected to perform KYC checks, but they are expected to understand the risks their business faces and ensure those risks are managed effectively.

Failure at this level is increasingly viewed as a governance lapse.

AML Accountability of Partners and Senior Management

Partners and senior executives act as the bridge between strategy and operations. Regulators expect them to:

• Embed AML controls into daily business processes

• Ensure revenue targets do not override compliance concerns

• Support escalation of high-risk cases

• Enforce consistent application of AML policies

In professional firms and real estate businesses, partners often have close client relationships. This makes their role critical in:

• Questioning unusual deal structures

• Supporting enhanced due diligence decisions

• Preventing “commercial pressure” on AML teams

The Expanding Role of Finance Teams in AML

Finance teams are now considered frontline AML gatekeepers, not back-office processors.

AML Expectations from Finance Teams

• Identifying unusual payment patterns

• Questioning large cash or third-party transfers

• Ensuring transaction records align with business purpose

• Supporting source-of-funds reviews

• Assisting with suspicious activity escalations

Because finance teams see money flows in real time, regulators expect them to act, not ignore, when red flags appear.

Key AML Duties for Real Estate Professionals

To support a risk-based AML framework, real estate professionals must apply controls consistently:

1. Know Your Customer (KYC)

• Verify buyer and seller identities

• Identify Ultimate Beneficial Owners (UBOs)

• Apply risk-based customer classification

2. Understand the Transaction

• Assess commercial rationale

• Identify over- or under-valued deals

• Question unnecessary complexity

3. Follow the Money

• Review source of funds

• Monitor offshore transfers and cash usage

• Trigger enhanced checks where needed

4. Ongoing Monitoring

• Monitor repeat client behavior

• Update risk profiles over time

• Escalate changes promptly

These steps rely on cooperation between sales, finance, and compliance teams.

Supervisors and Regulators: Driving Accountability

AML enforcement in the UAE is overseen 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 personal accountability expectations

• Challenged passive or nominal oversight

• Required evidence of senior involvement

• Focused inspections on governance effectiveness

In 2025, regulators assess how accountability works in practice, not just how it is described in policy documents.

Extra Scrutiny on Emerging and Weakly Regulated Markets

In developing real estate markets or sectors with limited AML maturity, authorities apply closer supervision.

Regulators closely monitor:

• Newly established agencies

• Businesses with low AML awareness

• Regions with enforcement challenges

Clear internal accountability helps prevent these segments from becoming entry points for illicit activity.

Practical Steps to Strengthen AML Accountability

To meet regulatory expectations, UAE companies should:

• Clearly define AML roles at all levels

• Document escalation and decision-making authority

• Provide AML training to directors and finance teams

• Align incentives with compliance objectives

• Conduct periodic AML governance reviews

• Seek independent AML assessments when needed

Many firms engage professional advisors to test whether accountability structures would withstand regulatory inspection.

Why Strong AML Accountability Is a Business Strength

Effective AML accountability:

• Reduces enforcement and penalty risk

• Improves regulatory inspection outcomes

• Enhances trust with banks and partners

• Supports sustainable growth

In 2025, regulators increasingly view strong AML governance as a hallmark of responsible leadership.

AML compliance in the UAE is no longer confined to the compliance department. Directors, partners, and finance teams all play essential roles in protecting businesses from money laundering and terrorist financing risks.

For real estate and other high-risk sectors, shared accountability—guided by a risk-based approach—is now a regulatory expectation, not a best practice. Companies that embrace this shift will be better positioned to meet scrutiny, avoid penalties, and operate with confidence in an evolving regulatory environment.