As the UAE tightens its anti–money laundering (AML) regulations heading into 2025, one requirement stands out across all sectors: accurate, complete, and high-quality data. Whether a business is in real estate, jewellery, legal services, corporate consultancy, or any other DNFBP category, regulatory expectations around data governance have significantly increased.

Authorities now demand clean, traceable, and verifiable records, because poor AML data quality directly contributes to undetected financial crime. For companies, this shift means enhancing internal controls, restructuring compliance processes, and relying more deeply on accounting and AML professionals such as Swenta to avoid penalties.

Why Data Quality Matters in AML – The 2025 Perspective

High-quality AML data is not just a regulatory expectation—it is the backbone of effective risk detection. Inaccurate information leads to:

• Missed red flags

• Faulty customer risk profiles

• Incomplete due diligence

• Reporting errors on goAML

• Weak monitoring capabilities

This creates opportunities for criminals to bypass controls, especially in sectors such as real estate, where the risk of money laundering remains high.

Why Real Estate Is a Key Target for Money Laundering

Real estate continues to be one of the most exploited DNFBP sectors. Criminals prefer property transactions because:

1. High-Value Deals Move Large Sums Easily

A single purchase can disguise millions in illicit funds.

2. Beneficial Ownership Can Be Hidden

Shell companies and proxies often obscure the real owner.

3. The Sector Had Historically Lower Regulation Than Banking

This gap provided opportunities for illegal financial flows.

4. Asset Conversion Makes Tracing Hard

Once dirty money becomes property, recovery becomes extremely difficult.

These risks make accurate records, transparent ownership structures, and quality data essential for compliance.

Understanding the Risk-Based Approach (RBA) in 2025

The UAE follows FATF’s global requirement that every DNFBP must implement a Risk-Based Approach. This means:

• Identifying ML/TF risks in each client and transaction

• Prioritizing resources on high-risk areas

• Applying Enhanced Due Diligence (EDD) where needed

• Maintaining evidence that decisions were risk-informed

Without accurate data, an RBA becomes ineffective. This is one of the core reasons why the UAE is enhancing its data quality demands in 2025.

Key AML Data Quality Requirements for 2025

Regulators are increasing expectations in several critical areas:

1. Accurate KYC & Beneficial Ownership Records

Businesses must ensure:

• Valid, updated identity documents

• Correct beneficial ownership details

• Verification of intermediaries

• Screening against sanctions and watchlists

Any gaps or inconsistencies can result in fines.

2. Complete Transaction Documentation

DNFBPs must record:

• Purpose of transaction

• Source of funds

• Supporting invoices and contracts

• Pricing justification

• Any unusual characteristics

Incomplete records are viewed as compliance failures.

3. Timely Updates & Ongoing Monitoring

Data cannot remain static. Businesses must:

• Periodically refresh client information

• Track client behavior for unusual changes

• Detect suspicious financial patterns

• Maintain updated risk scores

This is only possible when internal data is reliable.

4. Accurate goAML Submissions

Poor internal data leads to:

• Rejected Suspicious Transaction Reports (STRs)

• Inaccurate or incomplete filing

• Delays that trigger enforcement action

In 2025, goAML accuracy is a major focus of regulators.

5. Proper Record Retention

Businesses must retain all records for at least five years, including:

• KYC files

• Transaction data

• Monitoring logs

• Risk assessments

• Training records

Missing documents automatically count as non-compliance.

Supervisors Are Increasing Enforcement in 2025

The AMLD (Anti-Money Laundering & CFT Supervision Department) is intensifying its oversight through:

• More detailed inspections

• Data verification checks

• Sector-wide risk evaluations

• Penalties for inaccurate reporting

• Mandatory corrective action plans

In sectors with historically low AML maturity, such as jewellery traders or small real estate agencies, supervisory attention is even stricter.

Challenges in Emerging DNFBP Markets

Weak or developing markets often struggle with:

• Limited AML awareness

• Poor documentation practices

• Manual record-keeping

• Inconsistent due diligence processes

• Lack of structured risk assessments

This makes them higher targets for regulatory investigations in 2025.

Practical Steps to Improve AML Data Quality

Businesses should implement the following actions immediately:

✔ Build standardized due diligence checklists

Ensures consistency and accuracy across all client records.

✔ Use AML technology for verification and monitoring

Automates risk scoring and reduces human error.

✔ Train staff regularly

Employees must understand the importance of clean data and how to maintain it.

✔ Establish policies for high-risk customers

Documented procedures strengthen audit readiness.

✔ Maintain continuous monitoring

Regular reviews help detect changes in client behavior or risk level.

✔ Work with accounting & AML experts

Firms like Swenta help businesses strengthen governance, improve data accuracy, and comply with 2025 regulatory requirements.

In 2025, the UAE’s AML landscape demands precise, reliable, and well-structured data. As supervision becomes stricter, businesses cannot afford documentation gaps or inconsistent reporting. By improving data management practices and partnering with specialists such as Swenta, companies can stay compliant, avoid penalties, and operate with confidence in a highly regulated environment.