As the UAE strengthens its position as a global financial and business hub, anti-money laundering (AML) compliance expectations for professional service firms have increased significantly. In 2025, regulators are paying closer attention to accounting firms, audit practices, tax advisors, legal consultants, and other designated non-financial businesses and professions (DNFBPs).

For professional service firms, AML compliance is no longer a secondary obligation—it is a core risk management and governance responsibility. This article explores the key AML compliance challenges faced by professional service firms in the UAE, why certain sectors like real estate attract heightened scrutiny, and how firms can build effective, risk-based AML frameworks aligned with regulatory expectations.

Why Professional Service Firms Are Under Increased AML Scrutiny

Professional service firms play a critical role in business structuring, financial reporting, transactions, and advisory services. Because of this, they are often positioned close to the flow of funds and ownership structures, making them attractive gateways for illicit activity.

Regulators view these firms as:

• Gatekeepers to the financial system

• Enablers of complex corporate and cross-border structures

• Key identifiers of beneficial ownership and transaction intent

As a result, weaknesses in AML controls within professional firms can have wide-reaching consequences.

Why Real Estate Is Frequently Targeted by Criminals

Real estate continues to be one of the most scrutinized sectors under UAE AML regulations—and professional service firms advising real estate clients are directly impacted.

Criminals favor real estate because:

• Properties involve high-value transactions, allowing large sums to move at once

• The sector is historically less regulated than banking

• Ownership can be obscured through shell companies or nominees

• Once funds are invested in property, they become harder to trace or confiscate

In some countries, unchecked illicit investment has inflated property prices, harming communities and undermining trust in the legal system. UAE regulators are determined to prevent similar outcomes, which places additional AML pressure on advisors involved in property transactions.

Understanding the Risk-Based Approach (RBA)

At the center of UAE AML expectations is the risk-based approach (RBA).

Rather than applying identical checks to every client or transaction, RBA requires firms to:

• Identify where money laundering and terrorist financing risks are highest

• Apply enhanced controls to high-risk scenarios

• Use simplified measures for genuinely low-risk cases

According to FATF guidelines, professional service firms must assess risks related to:

• Client type

• Nature of services provided

• Geographic exposure

• Transaction size and complexity

In practice, this is one of the most challenging areas for firms to implement effectively.

Key AML Compliance Challenges for Professional Service Firms in 2025

1. Client Risk Assessment Gaps

Many firms struggle to conduct meaningful client risk assessments. Common issues include:

• Generic risk scoring models

• No differentiation between advisory and transactional clients

• Failure to reassess risk as client circumstances change

Without accurate risk profiling, AML controls lose effectiveness.

2. Weak KYC and Beneficial Ownership Identification

KYC remains a major challenge, particularly for complex corporate structures.

Regulators frequently identify:

• Incomplete identification of ultimate beneficial owners (UBOs)

• Overreliance on client-provided declarations

• Insufficient verification of control and ownership chains

For professional firms, missing UBO information is considered a serious compliance failure.

3. Difficulty Understanding Transaction Purpose

Professional service firms are expected to understand the commercial rationale behind transactions they advise on.

Red flags often overlooked include:

• Unusual transaction structures

• Deals that do not align with the client’s stated business activities

• Pricing that deviates significantly from market norms

Failure to question such activity signals weak AML judgment.

4. Source of Funds and Source of Wealth Challenges

Following the money is a regulatory priority.

Firms often face difficulties when:

• Funds originate from offshore jurisdictions

• Clients use layered payment structures

• Wealth accumulation cannot be clearly explained

In high-risk cases, enhanced due diligence is mandatory—but not always applied correctly.

5. Ongoing Monitoring Limitations

AML compliance is not a one-time onboarding exercise. Yet many firms lack:

• Periodic client reviews

• Ongoing transaction monitoring

• Mechanisms to detect changes in risk behavior

Long-standing client relationships are often the most neglected from a monitoring perspective.

6. Resource and Expertise Constraints

Smaller and mid-sized professional firms often struggle with:

• Limited dedicated compliance staff

• Rapid regulatory updates

• Balancing commercial pressures with compliance obligations

This creates a risk of unintentional non-compliance despite good intentions.

7. Training and Awareness Gaps

Even when policies exist, they fail without proper execution.

Common issues include:

• One-size-fits-all AML training

• Lack of role-specific guidance

• No real-life case studies relevant to professional services

Regulators increasingly expect evidence that staff understand and apply AML principles in daily work.

Role of Supervisors and Regulators in the UAE

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:

• Expanded inspections across DNFBP sectors

• Increased enforcement actions and fines

• Shifted toward outcome-based compliance assessments

Where sectors or firms show maturity gaps, stricter oversight and remediation requirements are applied.

Special Focus on Emerging and High-Risk Markets

Professional service firms operating in:

• Newly regulated sectors

• High-growth real estate markets

• Jurisdictions with weaker enforcement histories

face enhanced scrutiny. Regulators aim to prevent these areas from becoming entry points for illicit funds.

Practical Steps to Strengthen AML Compliance

Professional service firms can improve AML resilience by:

1. Enhancing Risk Assessments

• Conduct service-specific and client-specific risk reviews

• Update assessments annually or upon material changes

2. Strengthening KYC and UBO Processes

• Go beyond declarations

• Verify ownership through reliable, independent sources

3. Applying a True Risk-Based Approach

• Escalate checks for high-risk engagements

• Document decisions and justifications

4. Improving Monitoring and Documentation

• Review long-term clients periodically

• Maintain clear audit trails

5. Investing in Training and Advisory Support

Many firms work with experienced advisors such as Swenta to review AML frameworks, identify gaps, and align controls with UAE regulatory expectations—without disrupting core business operations.

In 2025, AML compliance for professional service firms in the UAE is no longer about having policies on paper. Regulators expect clear evidence of risk awareness, effective controls, and informed decision-making.

Firms that proactively address AML challenges—particularly around risk assessments, KYC, and monitoring—are far better positioned to withstand inspections, avoid penalties, and protect their professional reputation.

Strong AML compliance is not just a regulatory requirement; it is a marker of trust, professionalism, and long-term sustainability.