Corporate Service Providers (CSPs) in the UAE—including consultancy firms, company formation specialists, trust and fiduciary service providers, PRO firms, and outsourced compliance teams—are now under strict scrutiny in 2025. As the UAE strengthens its fight against financial crime, CSPs are expected to demonstrate strong Anti-Money Laundering (AML) systems, risk assessments, and continuous monitoring.

With global regulators turning their focus toward corporate structuring and business setup industries, CSPs must upgrade their compliance frameworks to avoid penalties, maintain reputation, and support clients legally and ethically.
Professional accounting firms like Swenta now play a vital role in helping CSPs build robust AML controls aligned with UAE and FATF expectations.

Why Corporate Service Providers Face Increased AML Scrutiny

CSPs handle services that can be exploited for money laundering, including:

• company formation and restructuring

• nominee arrangements

• corporate secretarial services

• bank account assistance

• virtual office services

• UBO (Ultimate Beneficial Owner) documentation

• cross-border business transactions

These touchpoints make CSPs vulnerable to exploitation by individuals or groups seeking to hide ownership, move illicit funds, or layer complex transactions.

The UAE has clearly moved CSPs into the high-risk category for AML supervision in 2025. This aligns with broader efforts to improve transparency, strengthen financial integrity, and build long-term trust in the jurisdiction.

Why Real Estate Is Highlighted as a Sample High-Risk Sector

Criminals continue to target real estate, and CSPs frequently work with clients in this industry. Understanding real estate risk helps CSPs strengthen their overall AML framework.

1. High-Value Transactions

Large transfers allow criminals to launder significant sums quickly.

2. Less Regulation Compared to the Banking Sector

Historically, real estate transactions involved fewer compliance checks.

3. Use of Complex Ownership Structures

Hidden owners and offshore entities make it easy to disguise funds.

4. Difficulty in Seizing Property Assets

Real estate, once purchased, becomes challenging to trace and recover.

These risks affect corporate service providers because many clients engage in real estate management, investment, leasing, or development. CSPs must identify when clients may be connected to high-risk industries and apply enhanced due diligence.

Understanding the Risk-Based Approach (RBA) for CSPs

FATF and UAE regulations require CSPs to apply a Risk-Based Approach—meaning they should allocate more time, scrutiny, and documentation to clients and transactions with higher AML/CTF risks.

RBA is not about applying the same rules to all clients. It involves:

• evaluating the client’s background

• identifying beneficial owners

• examining the nature and purpose of the client’s business

• understanding cross-border elements

• identifying unusual ownership structures

• assessing geographic exposure

AML advisors, including Swenta, help CSPs implement an RBA framework customized to their service offerings.

Key AML Responsibilities for Corporate Service Providers in UAE (2025)

CSPs must comply with UAE Cabinet Decisions, AML laws, and FATF standards. Below are the essential expectations:

1. Client Due Diligence (CDD) and Enhanced Due Diligence (EDD)

CSPs must verify:

• identity documents (Emirates ID, passport)

• trade licenses for corporate clients

• Ultimate Beneficial Owners (UBOs)

• source of funds and source of wealth

• nature and purpose of the business relationship

High-risk clients require deeper investigations, ongoing monitoring, and periodic reviews.

2. Understanding Client Intent and Transaction Purpose

CSPs must assess:

• why the client is forming a company

• whether the business purpose is reasonable

• whether the structure is unnecessarily complex

• whether the jurisdictional choices raise red flags

If the client cannot explain why they need certain structures or services, this may indicate potential ML/TF risks.

3. Monitoring Client Behavior and Financial Activities

AML duties do not end after onboarding. CSPs must continuously monitor:

• changes in ownership

• unusual financial patterns

• non-typical business transactions

• requests for nominee arrangements

• sudden restructuring without valid reasons

A proactive monitoring program is critical as per 2025 expectations.

4. Identifying Source of Funds

Red flags include:

• offshore transfers with unclear justification

• payments made by unrelated third parties

• cash deposits in business bank accounts

• frequent cross-border transfers that do not match business activities

CSPs must trace the financial flow whenever possible and document their findings.

5. Filing Suspicious Transaction Reports (STRs)

If something appears suspicious, CSPs must:

• file an STR through the goAML system

• document all investigative steps taken

• not notify the client (tipping off is illegal)

This requirement is heavily enforced in 2025.

Regulatory Bodies Leading AML Supervision in the UAE

Corporate Service Providers fall under the supervision of:

AMLD – Anti-Money Laundering & Combating the Financing of Terrorism Supervision Department

Established by the Central Bank, AMLD oversees AML compliance across DNFBPs, including CSPs.

AMLD responsibilities include:

• regulatory inspections

• compliance audits

• issuing guidelines

• levying penalties

• conducting awareness and training programs

The UAE has increased inspection frequency in 2025, making compliance essential for business continuity.

Special Focus in 2025: Weak or Emerging Segments of the CSP Sector

Authorities now monitor:

• newly licensed corporate service providers

• firms with low AML awareness

• companies with limited documentation systems

• service providers handling high-risk clients or industries

• CSPs operating in free zones lacking mature compliance systems

Strengthening AML awareness in these areas is a key national priority for UAE 2025.

Practical AML Steps CSPs Should Implement Immediately

To stay compliant and avoid penalties, CSPs must adopt:

✔ Tailored AML policies and procedures

✔ KYC and UBO verification checklists

✔ Automated tools for monitoring client transactions

✔ Regular staff training and certification

✔ Internal audits and periodic AML reviews

✔ Clear rules for escalation and reporting

✔ Secure record-keeping for a minimum of 5 years

✔ Enhanced Due Diligence (EDD) for high-risk clients

Swenta assists CSPs with AML framework development, policy creation, audits, and reporting—ensuring full UAE compliance.

2025 marks a turning point where corporate service providers must adopt stronger, clearer, and well-documented AML measures. With heightened regulatory expectations, CSPs cannot rely on basic KYC alone—they must implement comprehensive risk assessments, monitoring programs, and reporting systems.

Partnering with professional AML and accounting experts like Swenta ensures CSPs meet all obligations while maintaining smooth operations and protecting their reputations.