As the UAE continues strengthening its regulatory framework, AML record-keeping and reporting requirements have become more advanced, more structured, and more strictly enforced in 2025. Businesses across the country—especially DNFBPs, financial service providers, and high-risk sectors—must now demonstrate complete transparency in how they store, manage, and report customer and transaction data.

Audit and accounting firms like Swenta are playing a critical role in helping companies interpret these evolving rules and build systems that ensure ongoing compliance. With penalties increasing and supervisory reviews becoming more frequent, maintaining proper AML records and reporting suspicious activities accurately is no longer optional—it’s an essential part of doing business in the UAE.

This guide breaks down the latest AML expectations, best practices, and expert strategies for effective record-keeping and reporting in 2025.

Why AML Regulations Continue Tightening in the UAE

Money laundering remains a major global concern, and the UAE—being an international financial hub—has increased its vigilance. One area that has historically attracted illegal financial activity is real estate.

Why Real Estate Is a Preferred Target for Criminals

Criminals have long used real estate as a tool for laundering funds because:

1. High-value transactions allow rapid movement of large sums.

One property purchase can conceal millions in illicit funds.

2. Less oversight compared to traditional banking.

While banks follow strict AML rules, real estate transactions often involve third parties, making detection more difficult.

3. Ownership can be hidden or layered.

Shell companies, nominee buyers, or offshore structures obscure the real beneficiary.

4. Once money becomes property, tracing becomes difficult.

This “integration” stage makes it harder for regulators to follow the money trail.

These risks have pushed regulators to demand better documentation, more thorough due diligence, and stronger reporting processes from all businesses—not just real estate agents.

Understanding the Risk-Based Approach (RBA) in 2025

The UAE follows global FATF guidelines that require every business to adopt a Risk-Based Approach (RBA). This approach ensures companies allocate compliance resources efficiently by focusing on the transactions and customers most likely to involve illicit activity.

What the RBA Requires:

• Identify the risk level of each client.

• Assess transaction patterns for unusual or complex behavior.

• Apply Enhanced Due Diligence (EDD) where needed.

• Continuously monitor high-risk customers.

• Maintain detailed records that justify every compliance decision.

AML consultants and accounting experts support businesses in building RBA frameworks that meet the UAE’s evolving expectations.

Core AML Record-Keeping Standards for UAE Businesses in 2025

Proper record-keeping is the backbone of AML compliance. In 2025, regulators expect businesses to maintain accurate, complete, and retrievable records for extended periods.

Required Records Include:

1. Customer Due Diligence (CDD) Files

• Passports, IDs, Emirates ID

• Proof of address

• Beneficial ownership documents

• Risk assessment forms

• KYC questionnaires

2. Transaction Records

• Invoices

• Bank transfers

• Receipts

• Payment confirmations

• Any unusual transaction explanations

3. Internal AML Policies & Procedures

Businesses must maintain written policies covering:

• KYC processes

• EDD requirements

• Internal reporting flows

• Staff responsibilities

4. Training Records

Regulators expect proof that employees receive regular AML training.

5. goAML Reporting Evidence

Copies of:

• STRs (Suspicious Transaction Reports)

• SARs (Suspicious Activity Reports)

• ERRs (Entity Registration Reports)

• Correspondence with regulators

Record Retention Period

Most AML records must be preserved for at least five years, and some high-risk entities may be required to store data longer.

AML Reporting Standards: What Businesses Must Follow

Beyond maintaining records, businesses must report suspicious activity quickly and accurately.

Key Reporting Requirements Include:

1. Identifying Suspicious Activity Early

Unusual behavior can include:

• Sudden large cash transactions

• Complex ownership structures

• Unexplained third-party involvement

• Transfers from offshore jurisdictions

2. Filing STR/SAR Reports on goAML

Businesses must submit reports promptly through the UAE’s goAML portal.

3. Maintaining Internal Reporting Mechanisms

Employees should have a clear pathway to escalate suspicious findings to the compliance officer.

4. Avoiding Tipping-Off

Staff must never alert clients that they are being reported.

5. Ensuring Consistency Across Records

Any mismatch between operational documents and filed reports can trigger regulatory investigation.

Accounting firms like Swenta help companies prepare compliant reports and avoid serious compliance mistakes.

Supervisors & Regulators Increasing Monitoring in 2025

The UAE continues prioritizing AML and counter-terrorism financing (CFT). The AMLD, operating under the Central Bank of the UAE (CBUAE), oversees compliance across most business sectors.

Supervisory bodies focus heavily on:

• Newly established businesses

• DNFBPs (real estate, accounting, legal, gold & precious metals traders)

• Firms lacking AML awareness

• Regions with weaker historical enforcement

The goal is to build stronger compliance culture and eliminate sectors vulnerable to financial crime.

Best Practices for AML Record-Keeping in 2025 (From Accounting Experts)

1. Digitize all records with secure cloud storage.

Digital records improve accessibility and reduce loss risk.

2. Standardize KYC checklists.

Uniform documentation ensures accuracy and compliance.

3. Use automated transaction-monitoring tools.

Systems can identify red flags faster than manual checks.

4. Conduct periodic AML audits.

Internal and external reviews strengthen reporting consistency.

5. Train employees every quarter.

Frequent training ensures staff understand new regulations.

6. Document EVERY decision.

Regulators look for justification behind risk classification and due diligence.

7. Engage professional AML support.

Firms like Swenta help maintain compliant systems and manage ongoing reporting obligations.

Why Accounting Firms Are Essential for AML Compliance in 2025

Accounting firms bring expertise that most businesses lack internally:

• They understand both financial and regulatory expectations.

• They ensure record accuracy across all financial touchpoints.

• They prepare businesses for AML inspections.

• They manage goAML reporting without errors.

• They integrate AML controls with broader financial compliance frameworks.

With tightening enforcement in 2025, outsourcing AML compliance to qualified accounting experts is becoming the safest and most cost-effective strategy.

Compliance in the UAE is no longer limited to basic KYC procedures. In 2025, businesses must maintain structured AML records, file accurate goAML reports, and apply a thorough risk-based approach to every customer relationship.

By partnering with an experienced firm like Swenta, companies can build strong AML frameworks, protect themselves from regulatory penalties, and enhance trust with stakeholders and authorities.

Accurate record-keeping is not just a legal requirement—it is the foundation of financial integrity.