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Transaction Monitoring Challenges in UAE Businesses: What’s Changing in 2025

As the UAE continues to strengthen its anti-money laundering (AML) ecosystem, transaction monitoring has become one of the most closely examined areas during regulatory reviews. In 2025, businesses are no longer assessed only on whether they monitor transactions—but on how effectively they identify, analyze, and respond to suspicious activity.

Regulators now expect transaction monitoring systems to be risk-based, dynamic, and sector-aware. Static rules, generic alerts, and manual reviews without context are increasingly viewed as compliance weaknesses.

This article explores the key transaction monitoring challenges facing UAE businesses in 2025, what regulators are changing, and how organizations can adapt—especially in higher-risk sectors such as real estate.

Why Transaction Monitoring Is Under the Regulatory Spotlight in 2025

Transaction monitoring is the backbone of any AML program. It is how regulators determine whether a business can:

  • Detect unusual or suspicious behavior

  • Understand the economic purpose of transactions

  • Escalate risks appropriately

  • Prevent misuse of its services

In recent inspections, UAE authorities have identified recurring gaps such as poor alert quality, weak investigation processes, and insufficient documentation. As a result, expectations in 2025 are significantly higher.

Why Real Estate Transactions Pose Unique Monitoring Challenges

Real estate remains a high-risk sector for money laundering globally, and the UAE is no exception.

Criminals often favor property transactions because:

  • High deal values allow large sums to be moved quickly

  • Complex deal structures obscure the true source of funds

  • Use of third parties or corporate vehicles hides beneficial ownership

  • Asset conversion makes funds harder to trace or recover

Once illicit money is invested in property, tracing or freezing it becomes more difficult. This is why transaction monitoring in real estate must go beyond basic payment checks and focus on the overall transaction context.

What’s Changing in Transaction Monitoring in 2025

1. Shift From Rule-Based to Risk-Based Monitoring

Traditional rule-based systems generate alerts based on fixed thresholds. In 2025, regulators expect businesses to adopt a risk-based monitoring approach, where alerts are driven by:

  • Customer risk rating

  • Transaction type and size

  • Geographic exposure

  • Historical behavior patterns

High-risk clients and transactions should trigger deeper and faster reviews, while lower-risk activity can follow simplified controls.

2. Greater Emphasis on Context, Not Just Transactions

Monitoring a transaction in isolation is no longer sufficient. Businesses are expected to ask:

  • Does this transaction make commercial sense?

  • Is the pricing consistent with market norms?

  • Is the transaction structure unnecessarily complex?

In real estate, red flags include repeated quick resales, unexplained price variations, and funding from unrelated offshore entities.

3. Stronger Link Between KYC and Transaction Monitoring

One of the most common regulatory findings is disconnected systems—where KYC data is not effectively used in transaction monitoring.

In 2025, regulators expect businesses to:

  • Use customer risk profiles to calibrate alerts

  • Update monitoring scenarios when customer information changes

  • Align source-of-funds checks with transaction behavior

Know Your Customer is not a one-time process—it must inform ongoing monitoring.

Understanding the Risk-Based Approach in Monitoring

A Risk-Based Approach (RBA) means focusing monitoring resources where the risk is highest.

According to FATF guidance, businesses should:

  • Identify transaction types most vulnerable to abuse

  • Apply enhanced scrutiny to higher-risk clients and sectors

  • Regularly review and adjust monitoring thresholds

AML consultants in Dubai often help businesses redesign monitoring frameworks to reflect actual risk exposure rather than generic assumptions.

Key Transaction Monitoring Steps for Real Estate Professionals

To meet 2025 expectations, real estate businesses should strengthen monitoring across the following areas:

1. Robust Customer Due Diligence (KYC)

Monitoring starts with knowing who is involved. This includes:

  • Verifying buyers, sellers, and intermediaries

  • Identifying beneficial owners behind corporate structures

  • Understanding the client’s background and risk profile

Weak onboarding leads to ineffective monitoring.

2. Understanding the Transaction Purpose

Every transaction should have a clear economic rationale. Businesses should assess:

  • Why the property is being bought or sold

  • Whether the structure is unnecessarily layered

  • Whether the timing or pricing raises concerns

Unclear purpose is a key indicator of potential laundering.

3. Source of Funds Monitoring

Following the money is critical. Enhanced scrutiny is required when:

  • Funds originate from offshore or high-risk jurisdictions

  • Cash or cash-like instruments are involved

  • Payment routes do not align with the client profile

Transaction monitoring should confirm that funds align with declared source of wealth.

4. Ongoing Relationship Monitoring

Risk evolves over time. Monitoring should detect:

  • Changes in transaction patterns

  • Sudden increases in deal frequency or value

  • Behavior inconsistent with the customer’s profile

Periodic reviews help ensure monitoring remains relevant.

The Role of AML Consultants in Strengthening Monitoring Systems

Many UAE businesses struggle with over-alerting, under-reporting, or unclear escalation processes. AML consultants in the UAE assist by:

  • Reviewing transaction monitoring rules and scenarios

  • Reducing false positives while improving detection quality

  • Aligning systems with regulatory expectations

  • Preparing businesses for AML inspections

Firms like Swenta typically support clients by bridging the gap between regulatory theory and operational reality.

Regulatory Oversight and Supervisory Expectations

In the UAE, AML/CFT supervision is led by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD) under the Central Bank of the UAE.

Since 2020, AMLD has focused on:

  • Effectiveness of monitoring controls

  • Quality of suspicious transaction analysis

  • Timeliness and accuracy of reporting

In developing or high-growth sectors, regulators apply enhanced scrutiny until AML maturity improves.

Special Attention to Emerging or Weakly Regulated Markets

Transaction monitoring risks are higher where:

  • AML awareness is limited

  • New market entrants lack experience

  • Enforcement has historically been weak

Supervisors closely monitor these environments to prevent them from becoming safe havens for illicit activity.

Practical Ways to Improve Transaction Monitoring in 2025

Businesses can strengthen their monitoring frameworks by:

  • Using risk-based alert thresholds

  • Integrating KYC, risk scoring, and monitoring systems

  • Training staff to analyze alerts, not just clear them

  • Documenting decisions and escalation rationale

  • Conducting regular system testing and tuning

Continuous improvement is now a regulatory expectation.

In 2025, transaction monitoring is no longer about volume—it is about quality, judgment, and accountability. UAE regulators expect businesses to demonstrate that they understand their risks and can identify suspicious behavior in real time.

Organizations that invest in smarter, risk-based monitoring frameworks will not only reduce regulatory exposure but also build stronger operational resilience. With expert guidance and the right systems in place, transaction monitoring can move from a compliance burden to a strategic safeguard.

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Designing a Risk-Based AML Framework in the UAE: 2025 Practical Approach

As regulatory scrutiny intensifies across the UAE, businesses are no longer judged on whether they have an AML policy—but on whether their AML framework is risk-driven, effective, and defensible. In 2025, regulators expect companies to demonstrate a clear understanding of their money laundering and terrorist financing risks and to show how controls are proportionate to those risks.

This is where a Risk-Based AML Framework (RBA) becomes critical. Rather than applying generic compliance measures, UAE businesses must design AML systems that focus resources on higher-risk activities, clients, and transactions—while maintaining efficiency in lower-risk areas.

This guide explains how UAE businesses can design and implement a practical, regulator-ready risk-based AML framework in 2025, with special attention to high-risk sectors such as real estate.

Why a Risk-Based AML Framework Matters More in 2025

UAE regulators have significantly strengthened AML supervision in recent years, aligning enforcement with FATF recommendations and global best practices. During inspections, authorities now assess:

  • Whether risks are properly identified and documented

  • Whether controls match the actual risk profile

  • Whether senior management understands and oversees AML risks

  • Whether frameworks work in practice—not just on paper

A tick-box AML program is no longer sufficient. Businesses must show outcomes, not just policies.

Why Real Estate Remains a Key AML Risk Sector

Real estate continues to be a focal point for AML enforcement in the UAE—and for good reason.

Criminals are drawn to property transactions because:

  1. High transaction values allow large sums of money to be moved in a single deal

  2. Lower regulatory maturity compared to banks creates gaps in oversight

  3. Complex ownership structures make it easier to hide beneficial owners

  4. Asset conversion makes illicit funds harder to trace or confiscate

In several countries, unchecked real estate money laundering has distorted housing markets, pushed up prices, and damaged public trust. These risks explain why UAE regulators apply enhanced scrutiny to brokers, developers, and related professionals.

What Is a Risk-Based AML Approach?

A Risk-Based Approach (RBA) means applying AML controls based on the level of risk involved—rather than treating all customers and transactions the same.

Under FATF standards, every country—and every regulated business—must:

  • Identify money laundering and terrorist financing risks

  • Assess and categorize those risks

  • Apply enhanced controls to higher-risk areas

  • Apply simplified or standard controls where risk is low

In the UAE, this principle underpins regulatory expectations across financial institutions and DNFBPs, including real estate, accounting firms, and professional service providers.

Core Components of a Risk-Based AML Framework

1. Enterprise-Wide Risk Assessment (EWRA)

The foundation of any AML framework is a documented risk assessment that evaluates exposure across:

  • Customers and client types

  • Products and services

  • Delivery channels

  • Geographic exposure

This assessment must be updated regularly and used to justify control decisions.

2. Customer Risk Profiling and KYC

Know Your Customer procedures must go beyond identity verification. A strong framework includes:

  • Identification of beneficial owners

  • Risk scoring based on nationality, business activity, and transaction behavior

  • Enhanced Due Diligence for high-risk clients

  • Periodic review of customer profiles

Understanding who the client is—and why they are transacting—is essential.

3. Transaction Risk Analysis: Understanding the Deal

Risk-based AML requires context. Businesses should assess:

  • Whether a transaction is unusually complex

  • Whether pricing deviates from market norms

  • Whether deal structures lack commercial logic

In real estate, abnormal valuations, rapid resales, or unnecessary intermediaries often signal elevated risk.

4. Source of Funds and Source of Wealth Checks

Following the money is a core AML obligation. Higher-risk cases require:

  • Clear explanation of how funds were generated

  • Supporting documentation

  • Additional checks for offshore transfers or cash-heavy transactions

Failure to adequately verify funds is one of the most common regulatory findings.

5. Ongoing Monitoring, Not One-Time Checks

Risk does not end after onboarding. A robust framework includes:

  • Continuous transaction monitoring

  • Periodic client risk re-assessments

  • Alerts for unusual behavior or pattern changes

Static AML controls are viewed negatively during inspections.

The Role of AML Consultants in Framework Design

Designing a defensible AML framework requires technical expertise and regulatory awareness. AML consultants in the UAE help businesses:

  • Build customized risk assessment models

  • Align internal policies with UAE regulations and FATF standards

  • Prepare for AML inspections and supervisory reviews

  • Train staff on risk-based decision-making

Firms like Swenta often support clients by strengthening frameworks without disrupting daily operations—ensuring compliance remains practical and scalable.

Supervisory Oversight and Regulatory Expectations

In the UAE, AML/CFT supervision is led by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD), operating under the Central Bank of the UAE.

Since 2020, AMLD has intensified:

  • Sector-wide risk reviews

  • Thematic inspections

  • Enforcement actions for weak frameworks

Authorities now expect businesses to demonstrate maturity, not just compliance.

Extra Attention for Weak or Emerging Markets

In developing or rapidly expanding real estate markets, risks are higher due to:

  • New market entrants with limited AML experience

  • Weak internal controls

  • Inconsistent awareness of AML obligations

Supervisors closely monitor these areas to prevent them from becoming laundering hubs.

Practical Steps to Strengthen AML Risk Controls

To improve real-world effectiveness, businesses should:

  • Create standardized due diligence checklists

  • Implement automated risk-scoring tools

  • Conduct regular AML training sessions

  • Define escalation rules for high-risk cases

  • Review controls annually against regulatory updates

Risk-based AML is an ongoing process—not a one-time project.

In 2025, designing a risk-based AML framework is not optional for UAE businesses—it is a regulatory necessity. Companies that proactively assess risks, document decisions, and align controls with real exposure are far better positioned to withstand inspections and enforcement action.

A well-designed framework protects more than compliance—it safeguards reputation, operations, and long-term growth. With the right structure and expert guidance, businesses can turn AML from a regulatory burden into a strategic advantage.

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UAE AML Examination Readiness 2025: What Accounting Firms Advise Clients to Fix First

As AML enforcement in the UAE intensifies, 2025 is shaping up to be a critical year for regulatory inspections and examinations. Authorities are no longer satisfied with surface-level compliance or “tick-box” documentation. Instead, they are evaluating whether businesses truly understand, manage, and mitigate money laundering and terrorist financing risks.

Accounting and audit firms across the UAE are seeing a clear trend: many businesses fail AML examinations not because they lack policies, but because those policies are ineffective in practice. This article explains what regulators are focusing on in 2025 and what experienced accounting firms advise companies to fix first to stay inspection-ready.

Why AML Examinations Are Becoming Stricter in the UAE

The UAE has made significant progress in strengthening its AML/CFT framework in recent years. Regulatory bodies are now placing greater emphasis on how AML programs operate in real business environments, especially in higher-risk sectors such as real estate, trading, professional services, and DNFBPs.

Regulators are paying closer attention to:

  • Quality of risk assessments

  • Depth of customer due diligence

  • Consistency between policy and practice

  • Board and senior management involvement

  • Effectiveness of transaction monitoring and reporting

In short, having documents is no longer enough. Businesses must demonstrate that AML controls are embedded into daily operations.

Why Real Estate Remains a High-Risk Focus Area

Real estate continues to attract regulatory scrutiny globally, including in the UAE. Criminals prefer property transactions for several reasons.

First, real estate involves high-value assets, allowing large sums of money to move in a single transaction. Second, compared to banks, the sector has historically faced lighter operational controls, making it easier to hide beneficial ownership behind nominees, shell companies, or third parties. Third, once funds are invested in property, they become harder to trace and recover.

In many jurisdictions, unchecked financial crime in real estate has distorted markets and harmed local communities. As a result, UAE authorities now expect real estate professionals and related businesses to apply robust AML controls comparable to those in financial institutions.

The Risk-Based Approach: A Core Examination Pillar in 2025

A risk-based approach (RBA) sits at the center of AML examinations in 2025. Regulators want proof that businesses understand where their real risks lie and allocate resources accordingly.

Rather than applying the same checks to every customer or transaction, an RBA requires companies to:

  • Identify higher-risk customers, products, and jurisdictions

  • Apply enhanced due diligence where risk is elevated

  • Maintain proportionate controls for lower-risk activities

FATF standards require countries, supervisors, and regulated entities to adopt this approach. In the UAE, inspectors frequently test whether risk assessments are realistic, current, and actually used to guide decisions.

Accounting and AML advisory firms in Dubai regularly assist clients in redesigning risk frameworks that are practical, defensible, and aligned with regulatory expectations.

What Accounting Firms Advise Clients to Fix First

Based on recent examinations and regulatory feedback, accounting firms consistently identify the same problem areas during AML readiness reviews.

1. Weak or Outdated Risk Assessments

Many businesses rely on generic templates that do not reflect their actual operations. Regulators now expect risk assessments to:

  • Be business-specific

  • Consider customer profiles, transaction types, delivery channels, and geographies

  • Be reviewed and updated regularly

If your risk assessment has not changed in years, it is likely to fail an inspection.

2. Incomplete or Inconsistent KYC Files

Know Your Customer (KYC) remains a foundational AML requirement. During examinations, inspectors often find:

  • Missing identification documents

  • No verification of beneficial ownership

  • Lack of ongoing customer review

Businesses must verify not just who the customer is, but who ultimately owns or controls the funds, even when intermediaries are involved.

3. Poor Understanding of Transactions and Business Purpose

Regulators increasingly test whether companies understand why a customer is entering into a transaction. Red flags include:

  • Unusual deal structures

  • Prices that do not align with market norms

  • Complex arrangements with no clear commercial logic

Failure to question these indicators signals weak internal controls.

4. Inadequate Source of Funds Checks

One of the most common AML examination failures involves insufficient source-of-funds analysis. Inspectors expect businesses to:

  • Identify how customers generated their funds

  • Scrutinize cash-heavy or offshore transactions

  • Escalate higher-risk cases for enhanced review

Merely recording payment details is no longer sufficient.

5. Lack of Ongoing Monitoring

AML is not a one-time exercise. Regulators expect continuous monitoring of business relationships. This includes:

  • Reviewing changes in customer behavior

  • Identifying unusual transaction patterns

  • Updating risk profiles when circumstances change

Static compliance programs are a major red flag in 2025.

The Role of Supervisors and Regulators

Businesses are not expected to manage AML risk alone. In the UAE, supervision is led by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD), established under the Central Bank of the UAE.

Since 2020, AMLD has steadily increased oversight across sectors. Authorities are particularly focused on industries that are:

  • Rapidly expanding

  • New to AML obligations

  • Historically under-regulated

Where market maturity is still developing, inspections tend to be more frequent and detailed.

Special Attention to Emerging and Higher-Risk Markets

Regulators pay closer attention to:

  • Newly licensed firms

  • Businesses operating in high-risk jurisdictions

  • Sectors with limited AML awareness

These environments are more vulnerable to misuse, making strong supervision essential. Businesses operating in such areas must demonstrate heightened awareness and stronger controls.

Practical Steps to Improve AML Examination Readiness

Accounting firms typically recommend the following actions before an inspection:

  • Conduct an independent AML gap assessment

  • Update and document risk-based policies

  • Create standardized due diligence checklists

  • Implement technology for transaction monitoring

  • Train staff regularly with role-specific AML programs

  • Establish clear escalation and reporting procedures

Seeking guidance from experienced AML advisors in the UAE can significantly reduce regulatory risk and inspection stress.

How Accounting Firms Add Value to AML Readiness

Accounting and audit firms play a critical role in bridging the gap between regulation and practice. Firms like Swenta, working across audit, tax, and compliance advisory, help businesses translate legal requirements into operational systems that regulators expect to see.

The goal is not just to pass an inspection, but to build a sustainable AML framework that protects the business long-term.

AML examinations in the UAE are becoming deeper, more targeted, and more outcome-driven. In 2025, businesses that wait until an inspection notice arrives are already too late.

By addressing common weaknesses early and adopting a genuine risk-based approach, companies can move from reactive compliance to confident regulatory readiness.

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UAE Salary Outlook 2026: 4% Average Growth and Strong Pay Increases for In-Demand Roles

As the UAE economy continues to diversify and mature, salary structures across industries are evolving rapidly. Heading into 2026, businesses and professionals are preparing for a market defined by moderate overall wage growth and significant pay premiums for high-demand skills.

According to market indicators, the average salary increase in the UAE for 2026 is expected to be around 4%, with certain roles and sectors experiencing much higher increments due to talent shortages, regulatory complexity, and digital transformation.

This article breaks down what employers, finance leaders, and professionals should expect from the UAE salary landscape in 2026—and how businesses can plan strategically.

Overview: UAE Salary Growth Outlook for 2026

The UAE’s salary market in 2026 is shaped by several macro factors:

  • Continued economic diversification beyond oil

  • Increased foreign investment and regional headquarters expansion

  • Regulatory complexity in tax, compliance, and governance

  • Strong demand for digital, financial, and risk professionals

  • Controlled inflation compared to global averages

Together, these drivers point toward stable but selective salary growth, rather than across-the-board increases.

Average Salary Growth: Why 4% Is the New Benchmark

A projected 4% average salary increase reflects a balanced labor market:

  • Employers remain cost-conscious

  • Talent competition persists in niche areas

  • Performance-based increments are replacing blanket hikes

For many organizations, 4% represents a baseline adjustment to retain talent while maintaining operational margins.

However, averages hide the real story.

Roles Expected to See Above-Average Pay Increases

1. Finance, Accounting & Tax Professionals

As corporate tax, VAT, transfer pricing, and compliance requirements expand, qualified finance professionals remain in high demand.

Roles seeing strong salary momentum include:

  • Tax managers and tax advisors

  • Chartered accountants and CPAs

  • Financial controllers

  • Compliance and reporting specialists

Firms supporting finance and tax functions—such as Swenta—are seeing growing demand from businesses seeking experienced professionals who understand UAE regulations deeply.

2. Risk, Compliance & Governance Roles

With stronger regulatory enforcement across sectors, businesses are investing more in:

  • Internal audit professionals

  • Risk managers

  • Governance and compliance leads

These roles are no longer viewed as support functions—they are strategic safeguards, which directly influences compensation levels.

3. Technology & Digital Transformation Roles

Digital skills continue to command premium pay, especially in:

  • Data analytics

  • ERP and financial systems implementation

  • Cybersecurity and information risk

  • Automation and AI integration

Professionals who combine technical expertise with business or financial understanding are among the highest paid.

4. Senior Management & Leadership Positions

Executives with experience in:

  • Regional expansion

  • Regulatory navigation

  • M&A and restructuring

  • Cross-border operations

are seeing compensation packages grow faster than the market average, often through bonuses, equity, or long-term incentives rather than fixed salary alone.

Sectors Likely to Lead Salary Growth

Several industries are positioned to outperform the average salary growth rate:

  • Professional services (audit, tax, consulting)

  • Financial services and fintech

  • Technology and digital infrastructure

  • Healthcare and life sciences

  • Logistics and advanced manufacturing

These sectors benefit from regulatory complexity, skill shortages, or sustained investment, pushing salaries upward.

What This Means for Employers

For UAE businesses, the 2026 salary outlook highlights the need for strategic workforce planning, not reactive hiring.

Key employer considerations:

  • Benchmark roles regularly, not annually

  • Link pay increases to skills, not just tenure

  • Invest in retention for high-impact roles

  • Balance fixed pay with performance incentives

Organizations that fail to adjust compensation for critical roles risk higher attrition and rising replacement costs.

What This Means for Professionals

For employees and job seekers, 2026 presents opportunities—but only for those with relevant, future-ready skills.

Professionals can maximize earning potential by:

  • Upskilling in tax, compliance, digital, or analytics domains

  • Gaining internationally recognized certifications

  • Building sector-specific expertise

  • Demonstrating commercial and regulatory awareness

Salary growth is increasingly earned through specialization, not job hopping alone.

The Role of Professional Advisory Firms

Accounting, audit, and tax firms play a growing role in shaping compensation strategies by:

  • Advising on workforce structuring

  • Supporting regulatory compliance cost planning

  • Helping businesses align finance teams with future requirements

Advisory firms like Swenta often work alongside management to ensure that salary decisions support compliance, growth, and long-term sustainability, rather than short-term fixes.

Looking Ahead: A Selective but Strong Market

The UAE salary outlook for 2026 is clear:

  • 4% average growth sets the baseline

  • High-demand roles will outperform significantly

  • Skills, compliance knowledge, and leadership drive pay premiums

Businesses that understand these dynamics early will be better positioned to attract talent, control costs, and remain competitive in a tightening labor market.

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FTA Decision No. 9 of 2025: When Tax Refund Requests Can Be Rejected

Tax refunds are often seen by businesses as a straightforward administrative process. However, in the UAE, refund claims are increasingly subject to detailed scrutiny by the Federal Tax Authority (FTA).

With the issuance of FTA Decision No. 9 of 2025, the FTA has clarified specific conditions under which tax refund requests may be rejected, even when a refund appears valid at first glance. This decision marks a clear shift toward stricter compliance, stronger documentation standards, and higher accountability for taxable persons.

For businesses operating in the UAE, understanding this decision is essential to avoid delays, rejections, and compliance risks.

What Is FTA Decision No. 9 of 2025?

FTA Decision No. 9 of 2025 outlines the procedural and substantive grounds on which the FTA may refuse a tax refund application.

The decision applies primarily to:

  • VAT refund requests

  • Administrative refund claims

  • Refunds arising from overpaid or incorrectly declared tax

Its objective is to ensure that refunds are granted only where entitlement is clearly established and fully supported.

Why the FTA Is Tightening Refund Controls

Refunds involve a direct outflow of government revenue. As VAT systems mature, tax authorities globally—including the UAE—are placing greater emphasis on:

  • Preventing fraudulent or inflated refund claims

  • Ensuring accurate tax reporting

  • Encouraging disciplined record-keeping

  • Reducing misuse of refund mechanisms

FTA Decision No. 9 of 2025 reflects this broader policy direction by setting clear rejection triggers.

Key Reasons Tax Refund Requests Can Be Rejected

1. Incomplete or Inaccurate Documentation

Refund claims must be supported by clear, consistent, and verifiable records.

The FTA may reject a refund where:

  • Tax invoices are missing or invalid

  • Required supporting schedules are not submitted

  • Documents do not match VAT return data

Even minor inconsistencies can raise red flags during review.

2. Non-Compliance With VAT Registration Obligations

If the applicant:

  • Was not properly registered for VAT at the time of the transaction

  • Failed to update registration details

  • Operated outside the scope of registered activities

the FTA may determine that the refund claim lacks legal standing.

3. Outstanding Tax Liabilities or Penalties

FTA Decision No. 9 of 2025 reinforces the principle that:

Refunds are not processed in isolation.

Where a taxpayer has:

  • Unpaid VAT liabilities

  • Outstanding administrative penalties

  • Pending assessments

the FTA may offset the refund or reject the request entirely until obligations are settled.

4. Errors in VAT Returns or Refund Calculations

Refund claims derived from incorrect VAT returns are particularly vulnerable.

Common issues include:

  • Input VAT claimed on non-recoverable expenses

  • Mathematical errors

  • Misclassification of zero-rated or exempt supplies

If the underlying return is inaccurate, the refund claim will likely fail.

5. Failure to Respond to FTA Clarifications

During review, the FTA may request:

  • Additional explanations

  • Clarifying documents

  • Transaction-level breakdowns

If the taxpayer:

  • Misses deadlines

  • Provides incomplete responses

  • Fails to cooperate

the FTA is entitled to reject the refund application.

6. Refund Claims Linked to Artificial or Non-Genuine Transactions

The FTA has authority to deny refunds where transactions:

  • Lack economic substance

  • Appear structured solely to obtain refunds

  • Involve related parties without commercial justification

This is especially relevant in complex supply chains and group structures.

FTA’s Increasing Focus on Substance Over Form

One of the most important takeaways from Decision No. 9 of 2025 is the FTA’s emphasis on substance.

Refund claims are assessed based on:

  • Actual business activity

  • Commercial rationale

  • Consistency across filings

  • Audit trail integrity

A technically correct claim may still be rejected if it lacks commercial credibility.

Industries Most Affected by Refund Scrutiny

While the decision applies broadly, heightened scrutiny is commonly seen in:

  • Real estate and construction

  • Trading and import/export businesses

  • Professional services

  • Businesses with frequent refund positions

Complex transactions and high-value supplies naturally attract deeper review.

How Businesses Can Reduce Refund Rejection Risk

To align with FTA Decision No. 9 of 2025, businesses should:

  • Maintain clean, reconciled VAT records

  • Review refund positions before submission

  • Correct VAT returns prior to claiming refunds

  • Respond promptly to FTA queries

  • Perform internal VAT health checks

  • Seek professional review for large or complex claims

Many UAE businesses work with tax advisors such as Swenta to assess refund eligibility, validate documentation, and ensure submissions meet FTA expectations before filing.

What Happens After a Refund Is Rejected?

If a refund request is rejected:

  • The FTA will issue a formal decision

  • The taxpayer may submit objections within statutory timelines

  • Supporting evidence becomes critical at the reconsideration stage

Poor preparation at the initial stage often weakens appeal outcomes.

FTA Decision No. 9 of 2025 sends a clear message:

Tax refunds in the UAE are no longer routine—they are conditional, evidence-driven, and compliance-dependent.

Businesses that treat refunds as a compliance process rather than a formality will significantly reduce rejection risk and regulatory exposure.

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The Shift From Tick-Box AML to Outcome-Based Compliance in the UAE

For years, many UAE businesses treated Anti-Money Laundering (AML) compliance as a checklist exercise. Policies were drafted, forms were filled, and files were archived—often without a clear understanding of whether these controls actually prevented financial crime.

That era is ending.

In 2025, UAE regulators have clearly moved toward outcome-based AML compliance, where the focus is no longer on paperwork, but on real-world effectiveness. Businesses are now expected to demonstrate that their AML frameworks actively identify, assess, and mitigate risk.

This shift has significant implications—especially for higher-risk sectors such as real estate, professional services, and DNFBPs.

What Is Tick-Box AML Compliance?

Tick-box AML refers to a compliance approach where businesses:

  • Follow standard templates without customization

  • Apply identical checks to all clients

  • Focus on documentation rather than risk

  • Treat AML as a regulatory burden, not a business function

While this approach may create the appearance of compliance, it often fails to detect actual money laundering risks.

Regulators across the UAE have recognized that such systems are ineffective—particularly against sophisticated financial crime.

Why UAE Regulators Are Pushing Outcome-Based AML

Outcome-based compliance focuses on results, not rules alone.

Authorities now ask:

  • Are risks properly identified?

  • Are controls proportionate to risk?

  • Are suspicious activities detected and escalated?

  • Does the AML framework evolve as the business grows?

This aligns with FATF effectiveness standards, which emphasize whether AML measures actually prevent misuse of the financial system.

Why Real Estate Remains Under the Spotlight

Real estate continues to be one of the most scrutinized sectors under outcome-based AML reviews.

Why criminals prefer real estate

Real estate is attractive to criminals because:

  1. High transaction values
    Large amounts can be moved through a single deal.

  2. Complex ownership layers
    Shell companies, nominees, and third-party buyers can hide true ownership.

  3. Historically lighter controls than banking
    Although improving, regulation matured later than financial institutions.

  4. Asset conversion advantage
    Once funds are invested in property, tracing and recovery become difficult.

In some jurisdictions, unchecked money laundering has even inflated property prices, harming communities and legitimate buyers. This is why UAE regulators now expect real estate professionals to act as frontline AML gatekeepers.

Outcome-Based AML and the Risk-Based Approach (RBA)

At the heart of outcome-based compliance is the risk-based approach.

What is a Risk-Based Approach?

A risk-based approach means directing AML efforts where risks are highest—rather than treating all transactions equally.

According to FATF guidance, businesses must:

  • Identify money laundering and terrorist financing risks

  • Assess the level of exposure

  • Apply stronger controls to higher-risk scenarios

  • Use simplified measures for lower-risk cases

This ensures resources are used effectively and compliance efforts deliver measurable outcomes.

Key AML Expectations for Real Estate Professionals

To meet outcome-based standards, real estate businesses must demonstrate the following:

1. Meaningful KYC and Beneficial Ownership Checks

Authorities now assess whether:

  • Customer identities are verified accurately

  • Ultimate beneficial owners are clearly identified

  • Ownership structures are understood—not just recorded

Incomplete or outdated KYC files are viewed as systemic AML weaknesses.

2. Understanding the Transaction, Not Just the Client

Outcome-based AML requires professionals to assess:

  • The purpose of the transaction

  • Whether pricing aligns with market value

  • Why the structure is complex, if applicable

Deals that are unusually structured or priced should trigger enhanced scrutiny, not silent approval.

3. Source of Funds and Source of Wealth Analysis

Following the money is essential.

Regulators expect:

  • Clear documentation of where funds originate

  • Additional checks for cash payments or offshore transfers

  • Escalation where explanations lack credibility

Weak source-of-funds controls remain a leading cause of regulatory action.

4. Ongoing Monitoring, Not One-Time Checks

AML obligations do not end after onboarding.

Authorities review whether businesses:

  • Monitor repeat client behavior

  • Update risk profiles periodically

  • Identify changes in transaction patterns

  • Maintain internal escalation procedures

AML programs that stop at onboarding fail outcome-based evaluations.

Role of Supervisors and Regulators in the UAE

The Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD), established under the Central Bank of the UAE (CBUAE), plays a central role in enforcing outcome-based AML compliance.

Since 2020, AMLD has:

  • Expanded inspections beyond banks

  • Strengthened enforcement across DNFBPs

  • Focused on effectiveness rather than formalities

  • Increased expectations for governance and internal controls

Where AML maturity is still developing, regulatory scrutiny increases rather than relaxes.

Special Attention to Emerging or Weakly Regulated Markets

Outcome-based AML supervision places heightened focus on:

  • Newly formed businesses

  • Rapidly expanding real estate markets

  • Sectors with limited AML awareness

  • Regions with weaker historical enforcement

These environments can become safe havens for illicit activity if controls are not strengthened early.

How Businesses Can Transition to Outcome-Based AML

To move beyond tick-box compliance, businesses should:

  • Conduct detailed AML risk assessments

  • Customize AML controls to actual business activities

  • Train staff to recognize red flags and escalation triggers

  • Implement transaction monitoring mechanisms

  • Review AML frameworks regularly

  • Perform internal AML gap assessments

Many UAE businesses work with AML advisors to test whether their programs meet regulatory expectations. Firms like Swenta, operating across audit, accounting, tax, and compliance advisory, support organizations in aligning AML frameworks with practical, inspection-ready standards—without over-engineering compliance.

The UAE’s shift from tick-box AML to outcome-based compliance reflects a broader global reality:

AML compliance is no longer about what you document—it’s about what you prevent.

Businesses that embed risk awareness into operations, decision-making, and governance will not only reduce regulatory exposure but also strengthen long-term trust with regulators, partners, and investors.

Categories
Uncategorized

How UAE Authorities Evaluate AML Programs in 2025: Practical Insights for Businesses

Anti-Money Laundering (AML) enforcement in the UAE has entered a new phase. In 2025, regulators are no longer satisfied with written policies or generic compliance manuals. Instead, they assess how effectively AML programs operate in real business environments.

For UAE companies, this shift means one thing: AML programs must be demonstrably effective, risk-driven, and embedded into daily operations.

This guide explains how UAE authorities evaluate AML programs in 2025, what they look for during inspections, and how businesses can strengthen their compliance posture.

Why AML Program Evaluations Are Becoming Stricter

Several developments are shaping regulatory expectations:

  • Alignment with FATF effectiveness standards

  • Expansion of AML supervision beyond banks

  • Increased inspections of DNFBPs and professional service providers

  • Higher penalties for weak or superficial compliance

  • Focus on outcomes rather than documentation

Authorities now evaluate whether an AML framework actually prevents financial crime, not just whether it exists.

Why Real Estate Remains a High-Risk Sector

Real estate continues to attract close regulatory scrutiny in AML program evaluations.

Why criminals target real estate

Criminals favor real estate because:

  1. High transaction values
    Large sums can be moved in a single deal.

  2. Complex ownership structures
    Shell companies, nominees, and offshore entities obscure true ownership.

  3. Historically lighter oversight than banks
    While controls have improved, the sector matured later in AML enforcement.

  4. Asset conversion advantage
    Once illicit funds are invested in property, tracing and seizure become more difficult.

This activity doesn’t just distort financial systems—it drives up property prices, damages communities, and undermines trust in markets. Regulators now expect real estate professionals to act as active AML gatekeepers, not passive participants.

How UAE Authorities Assess AML Programs in 2025

AML evaluations in 2025 focus on five practical pillars:

1. Risk-Based Approach (RBA): From Theory to Practice

Authorities start by asking one fundamental question:

“Does your AML program reflect your actual risk exposure?”

They assess:

  • Whether the business has a documented AML risk assessment

  • If customer, geographic, and transaction risks are clearly identified

  • How high-risk cases are differentiated from low-risk ones

  • Whether controls increase proportionately with risk

Applying the same checks to every client is now viewed as a compliance weakness, not a safeguard.

2. Customer Due Diligence and Beneficial Ownership

KYC is no longer a box-ticking exercise.

During evaluations, regulators examine:

  • Accuracy and completeness of customer identification

  • Verification of ultimate beneficial owners (UBOs)

  • Documentation supporting ownership structures

  • Timeliness of KYC updates

Outdated or incomplete KYC files are among the most common reasons AML programs fail inspections.

3. Understanding Transactions, Not Just Identities

Regulators increasingly test whether businesses understand the logic of transactions.

They look for evidence that teams:

  • Question unusually structured deals

  • Identify pricing inconsistencies

  • Scrutinize layered or complex transactions

  • Recognize behavior that deviates from normal patterns

Knowing the client is not enough—knowing the transaction is essential.

4. Source of Funds and Source of Wealth Controls

Following the money is a core expectation in 2025.

Authorities assess whether AML programs:

  • Clearly document source of funds

  • Obtain supporting evidence for large or unusual payments

  • Apply enhanced checks for offshore transfers or cash involvement

  • Escalate unexplained or inconsistent funding sources

Weak source-of-funds controls are treated as serious AML failures.

5. Ongoing Monitoring and Internal Controls

AML compliance must be continuous, not static.

Regulators expect:

  • Periodic risk reassessments

  • Monitoring of ongoing client behavior

  • Internal escalation procedures

  • Suspicious activity reporting mechanisms

  • Regular AML training for staff

AML programs that stop at onboarding fail modern regulatory tests.

Role of AMLD and Supervisory Authorities

The Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD) under the Central Bank of the UAE (CBUAE) leads AML supervision across multiple sectors.

Since 2020, AMLD has:

  • Expanded inspection scope

  • Increased enforcement depth

  • Focused heavily on DNFBPs and real estate

  • Adopted risk-based supervisory methodologies

Where AML maturity is still developing, supervision becomes more intensive, not less.

Heightened Focus on Emerging and High-Risk Markets

AML evaluations place extra attention on:

  • Newly established businesses

  • Rapidly growing firms

  • Sectors with limited AML awareness

  • Regions with weak historical enforcement

These environments are seen as potential entry points for illicit activity, requiring stronger controls.

Common Weaknesses Identified During AML Reviews

Across inspections, regulators frequently identify:

  • Generic AML policies copied from templates

  • No documented risk assessment

  • Weak beneficial ownership checks

  • Inadequate source-of-funds analysis

  • Lack of staff training

  • No internal escalation framework

Such gaps often lead to corrective action plans, fines, or enhanced supervision.

How Businesses Can Strengthen Their AML Programs

To meet regulatory expectations in 2025, businesses should:

  • Conduct detailed AML risk assessments

  • Maintain clear KYC and due diligence checklists

  • Train employees on red flags and escalation

  • Implement transaction monitoring tools

  • Review AML frameworks regularly

  • Perform internal AML gap assessments

Many companies work with AML advisors in the UAE to test their programs against inspection standards. Firms like Swenta, operating across audit, accounting, and compliance advisory, support businesses in aligning AML frameworks with real regulatory expectations, not just theoretical compliance.

Anti-Money Laundering (AML) enforcement in the UAE has entered a new phase. In 2025, regulators are no longer satisfied with written policies or generic compliance manuals. Instead, they assess how effectively AML programs operate in real business environments.

For UAE companies, this shift means one thing: AML programs must be demonstrably effective, risk-driven, and embedded into daily operations.

This guide explains how UAE authorities evaluate AML programs in 2025, what they look for during inspections, and how businesses can strengthen their compliance posture.

Why AML Program Evaluations Are Becoming Stricter

Several developments are shaping regulatory expectations:

  • Alignment with FATF effectiveness standards

  • Expansion of AML supervision beyond banks

  • Increased inspections of DNFBPs and professional service providers

  • Higher penalties for weak or superficial compliance

  • Focus on outcomes rather than documentation

Authorities now evaluate whether an AML framework actually prevents financial crime, not just whether it exists.

Why Real Estate Remains a High-Risk Sector

Real estate continues to attract close regulatory scrutiny in AML program evaluations.

Why criminals target real estate

Criminals favor real estate because:

  1. High transaction values
    Large sums can be moved in a single deal.

  2. Complex ownership structures
    Shell companies, nominees, and offshore entities obscure true ownership.

  3. Historically lighter oversight than banks
    While controls have improved, the sector matured later in AML enforcement.

  4. Asset conversion advantage
    Once illicit funds are invested in property, tracing and seizure become more difficult.

This activity doesn’t just distort financial systems—it drives up property prices, damages communities, and undermines trust in markets. Regulators now expect real estate professionals to act as active AML gatekeepers, not passive participants.

How UAE Authorities Assess AML Programs in 2025

AML evaluations in 2025 focus on five practical pillars:

1. Risk-Based Approach (RBA): From Theory to Practice

Authorities start by asking one fundamental question:

“Does your AML program reflect your actual risk exposure?”

They assess:

  • Whether the business has a documented AML risk assessment

  • If customer, geographic, and transaction risks are clearly identified

  • How high-risk cases are differentiated from low-risk ones

  • Whether controls increase proportionately with risk

Applying the same checks to every client is now viewed as a compliance weakness, not a safeguard.

2. Customer Due Diligence and Beneficial Ownership

KYC is no longer a box-ticking exercise.

During evaluations, regulators examine:

  • Accuracy and completeness of customer identification

  • Verification of ultimate beneficial owners (UBOs)

  • Documentation supporting ownership structures

  • Timeliness of KYC updates

Outdated or incomplete KYC files are among the most common reasons AML programs fail inspections.

3. Understanding Transactions, Not Just Identities

Regulators increasingly test whether businesses understand the logic of transactions.

They look for evidence that teams:

  • Question unusually structured deals

  • Identify pricing inconsistencies

  • Scrutinize layered or complex transactions

  • Recognize behavior that deviates from normal patterns

Knowing the client is not enough—knowing the transaction is essential.

4. Source of Funds and Source of Wealth Controls

Following the money is a core expectation in 2025.

Authorities assess whether AML programs:

  • Clearly document source of funds

  • Obtain supporting evidence for large or unusual payments

  • Apply enhanced checks for offshore transfers or cash involvement

  • Escalate unexplained or inconsistent funding sources

Weak source-of-funds controls are treated as serious AML failures.

5. Ongoing Monitoring and Internal Controls

AML compliance must be continuous, not static.

Regulators expect:

  • Periodic risk reassessments

  • Monitoring of ongoing client behavior

  • Internal escalation procedures

  • Suspicious activity reporting mechanisms

  • Regular AML training for staff

AML programs that stop at onboarding fail modern regulatory tests.

Role of AMLD and Supervisory Authorities

The Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD) under the Central Bank of the UAE (CBUAE) leads AML supervision across multiple sectors.

Since 2020, AMLD has:

  • Expanded inspection scope

  • Increased enforcement depth

  • Focused heavily on DNFBPs and real estate

  • Adopted risk-based supervisory methodologies

Where AML maturity is still developing, supervision becomes more intensive, not less.

Heightened Focus on Emerging and High-Risk Markets

AML evaluations place extra attention on:

  • Newly established businesses

  • Rapidly growing firms

  • Sectors with limited AML awareness

  • Regions with weak historical enforcement

These environments are seen as potential entry points for illicit activity, requiring stronger controls.

Common Weaknesses Identified During AML Reviews

Across inspections, regulators frequently identify:

  • Generic AML policies copied from templates

  • No documented risk assessment

  • Weak beneficial ownership checks

  • Inadequate source-of-funds analysis

  • Lack of staff training

  • No internal escalation framework

Such gaps often lead to corrective action plans, fines, or enhanced supervision.

How Businesses Can Strengthen Their AML Programs

To meet regulatory expectations in 2025, businesses should:

  • Conduct detailed AML risk assessments

  • Maintain clear KYC and due diligence checklists

  • Train employees on red flags and escalation

  • Implement transaction monitoring tools

  • Review AML frameworks regularly

  • Perform internal AML gap assessments

Many companies work with AML advisors in the UAE to test their programs against inspection standards. Firms like Swenta, operating across audit, accounting, and compliance advisory, support businesses in aligning AML frameworks with real regulatory expectations, not just theoretical compliance.

In 2025, UAE authorities are no longer asking “Do you have an AML program?”

They are asking:

“Can your AML program actually prevent financial crime?”

Businesses that embed AML into decision-making, operations, and culture will not only avoid penalties—but will also gain long-term credibility with regulators, partners, and stakeholders.

Categories
Uncategorized

UAE AML Supervision Trends 2025: What Regulators Expect During Inspections

AML supervision in the UAE has evolved rapidly over the past few years. By 2025, inspections are no longer routine compliance checks—they are deep, risk-driven examinations of how businesses actually operate.

Regulators are moving away from policy-only reviews and focusing on evidence, behavior, and effectiveness. Businesses that fail to demonstrate real AML implementation now face fines, corrective action plans, or even license restrictions.

This guide explains how AML supervision is changing in the UAE, what regulators expect during inspections, and how businesses can prepare effectively.

Why AML Supervision Is Intensifying in the UAE

Several factors are driving stricter AML inspections:

  • UAE’s commitment to FATF alignment

  • Increased international scrutiny of high-risk sectors

  • Expansion of DNFBP supervision (including real estate and professional services)

  • Improved regulatory tools and inspection methodologies

  • Shift from awareness-based supervision to outcome-based enforcement

In 2025, regulators expect businesses to prove AML compliance works in practice, not just on paper.

Why Real Estate Remains a Key Inspection Focus

Real estate continues to receive heightened supervisory attention—and for good reason.

Why criminals target real estate

Criminal networks favor real estate transactions because:

  1. High-value assets
    Large amounts of money can be moved in a single transaction.

  2. Historically lighter controls than banking
    Although improving, real estate AML frameworks matured later than financial institutions.

  3. Complex ownership structures
    Shell companies, nominees, and offshore vehicles obscure beneficial ownership.

  4. Difficulty in tracing assets post-purchase
    Once funds are converted into property, recovery becomes more complex.

Unchecked illicit investment doesn’t just distort financial records—it inflates property prices, harms communities, and undermines legal systems. Regulators now expect real estate professionals to act as frontline AML gatekeepers.

What Regulators Look for During AML Inspections in 2025

AML inspections in 2025 focus on five core areas:

1. Risk-Based Approach (RBA) in Action

A risk-based approach is no longer optional—it is the foundation of AML supervision.

Regulators assess:

  • Whether the business has conducted a documented AML risk assessment

  • If customer, geographic, and transaction risks are clearly defined

  • Whether higher-risk cases receive enhanced controls

  • If low-risk relationships are justified with evidence

Applying identical checks to every client is now seen as a compliance failure, not a strength.

2. KYC and Beneficial Ownership Controls

During inspections, regulators examine KYC files in detail.

They expect to see:

  • Verified identity documents for buyers and sellers

  • Clear identification of the ultimate beneficial owner (UBO)

  • Evidence of ownership verification for corporate clients

  • Regular updates to customer records

Missing, outdated, or inconsistent KYC documentation is one of the most common inspection findings.

3. Understanding the Transaction, Not Just the Client

Regulators now ask: “Do you understand why this transaction makes sense?”

Inspection teams assess whether businesses:

  • Question unusual deal structures

  • Identify pricing inconsistencies

  • Investigate complex or layered transactions

  • Recognize red flags beyond basic documentation

A technically complete KYC file means little if the transaction itself raises unanswered questions.

4. Source of Funds and Source of Wealth Checks

AML inspections increasingly focus on how funds move, not just who the client is.

Inspectors expect:

  • Clear source-of-funds explanations

  • Supporting documentation for large transactions

  • Enhanced checks for offshore transfers or cash involvement

  • Escalation of unexplained or high-risk funding sources

Failure to follow the money trail is viewed as a critical compliance weakness.

5. Ongoing Monitoring and Internal Controls

AML compliance does not stop after onboarding.

Regulators check whether businesses:

  • Monitor repeat client behavior

  • Reassess risk periodically

  • Update KYC records

  • Escalate suspicious changes

  • Maintain internal reporting procedures

Static compliance frameworks are no longer acceptable.

Role of AMLD and Supervisory Authorities

In the UAE, AML/CFT supervision 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, AMLD has:

  • Expanded sector coverage

  • Increased inspection depth

  • Strengthened enforcement mechanisms

  • Focused heavily on DNFBPs, real estate, and emerging sectors

Where industries are still developing AML maturity, supervision is tighter—not lighter.

Special Attention on Emerging and High-Risk Markets

AML inspectors pay close attention to:

  • Newly established businesses

  • Rapidly growing agencies

  • Firms with limited AML experience

  • Regions with prior enforcement concerns

These areas are viewed as potential entry points for illicit activity, requiring enhanced supervisory oversight.

Common Inspection Failures Seen in 2025

Across recent inspections, regulators repeatedly identify:

  • Generic AML policies copied from templates

  • No documented AML risk assessment

  • Weak UBO identification

  • Inadequate source-of-funds checks

  • Lack of staff AML training

  • No internal escalation procedures

These gaps often lead to corrective action plans or financial penalties.

How Businesses Can Prepare for AML Inspections

To reduce inspection risk, businesses should:

  • Maintain updated AML risk assessments

  • Create clear KYC and due diligence checklists

  • Train staff regularly on red flags

  • Use technology for transaction monitoring

  • Establish internal escalation and reporting rules

  • Conduct internal AML reviews

Many businesses engage AML advisors in the UAE to stress-test their compliance frameworks and prepare for inspections.

Firms like Swenta, operating across audit, accounting, and compliance advisory, often assist organizations in aligning AML systems with regulatory inspection expectations rather than theoretical standards.

AML supervision in the UAE has evolved rapidly over the past few years. By 2025, inspections are no longer routine compliance checks—they are deep, risk-driven examinations of how businesses actually operate.

Regulators are moving away from policy-only reviews and focusing on evidence, behavior, and effectiveness. Businesses that fail to demonstrate real AML implementation now face fines, corrective action plans, or even license restrictions.

This guide explains how AML supervision is changing in the UAE, what regulators expect during inspections, and how businesses can prepare effectively.

Why AML Supervision Is Intensifying in the UAE

Several factors are driving stricter AML inspections:

  • UAE’s commitment to FATF alignment

  • Increased international scrutiny of high-risk sectors

  • Expansion of DNFBP supervision (including real estate and professional services)

  • Improved regulatory tools and inspection methodologies

  • Shift from awareness-based supervision to outcome-based enforcement

In 2025, regulators expect businesses to prove AML compliance works in practice, not just on paper.

Why Real Estate Remains a Key Inspection Focus

Real estate continues to receive heightened supervisory attention—and for good reason.

Why criminals target real estate

Criminal networks favor real estate transactions because:

  1. High-value assets
    Large amounts of money can be moved in a single transaction.

  2. Historically lighter controls than banking
    Although improving, real estate AML frameworks matured later than financial institutions.

  3. Complex ownership structures
    Shell companies, nominees, and offshore vehicles obscure beneficial ownership.

  4. Difficulty in tracing assets post-purchase
    Once funds are converted into property, recovery becomes more complex.

Unchecked illicit investment doesn’t just distort financial records—it inflates property prices, harms communities, and undermines legal systems. Regulators now expect real estate professionals to act as frontline AML gatekeepers.

What Regulators Look for During AML Inspections in 2025

AML inspections in 2025 focus on five core areas:

1. Risk-Based Approach (RBA) in Action

A risk-based approach is no longer optional—it is the foundation of AML supervision.

Regulators assess:

  • Whether the business has conducted a documented AML risk assessment

  • If customer, geographic, and transaction risks are clearly defined

  • Whether higher-risk cases receive enhanced controls

  • If low-risk relationships are justified with evidence

Applying identical checks to every client is now seen as a compliance failure, not a strength.

2. KYC and Beneficial Ownership Controls

During inspections, regulators examine KYC files in detail.

They expect to see:

  • Verified identity documents for buyers and sellers

  • Clear identification of the ultimate beneficial owner (UBO)

  • Evidence of ownership verification for corporate clients

  • Regular updates to customer records

Missing, outdated, or inconsistent KYC documentation is one of the most common inspection findings.

3. Understanding the Transaction, Not Just the Client

Regulators now ask: “Do you understand why this transaction makes sense?”

Inspection teams assess whether businesses:

  • Question unusual deal structures

  • Identify pricing inconsistencies

  • Investigate complex or layered transactions

  • Recognize red flags beyond basic documentation

A technically complete KYC file means little if the transaction itself raises unanswered questions.

4. Source of Funds and Source of Wealth Checks

AML inspections increasingly focus on how funds move, not just who the client is.

Inspectors expect:

  • Clear source-of-funds explanations

  • Supporting documentation for large transactions

  • Enhanced checks for offshore transfers or cash involvement

  • Escalation of unexplained or high-risk funding sources

Failure to follow the money trail is viewed as a critical compliance weakness.

5. Ongoing Monitoring and Internal Controls

AML compliance does not stop after onboarding.

Regulators check whether businesses:

  • Monitor repeat client behavior

  • Reassess risk periodically

  • Update KYC records

  • Escalate suspicious changes

  • Maintain internal reporting procedures

Static compliance frameworks are no longer acceptable.

Role of AMLD and Supervisory Authorities

In the UAE, AML/CFT supervision 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, AMLD has:

  • Expanded sector coverage

  • Increased inspection depth

  • Strengthened enforcement mechanisms

  • Focused heavily on DNFBPs, real estate, and emerging sectors

Where industries are still developing AML maturity, supervision is tighter—not lighter.

Special Attention on Emerging and High-Risk Markets

AML inspectors pay close attention to:

  • Newly established businesses

  • Rapidly growing agencies

  • Firms with limited AML experience

  • Regions with prior enforcement concerns

These areas are viewed as potential entry points for illicit activity, requiring enhanced supervisory oversight.

Common Inspection Failures Seen in 2025

Across recent inspections, regulators repeatedly identify:

  • Generic AML policies copied from templates

  • No documented AML risk assessment

  • Weak UBO identification

  • Inadequate source-of-funds checks

  • Lack of staff AML training

  • No internal escalation procedures

These gaps often lead to corrective action plans or financial penalties.

How Businesses Can Prepare for AML Inspections

To reduce inspection risk, businesses should:

  • Maintain updated AML risk assessments

  • Create clear KYC and due diligence checklists

  • Train staff regularly on red flags

  • Use technology for transaction monitoring

  • Establish internal escalation and reporting rules

  • Conduct internal AML reviews

Many businesses engage AML advisors in the UAE to stress-test their compliance frameworks and prepare for inspections.

Firms like Swenta, operating across audit, accounting, and compliance advisory, often assist organizations in aligning AML systems with regulatory inspection expectations rather than theoretical standards.

AML supervision in the UAE has entered a results-driven phase.

In 2025, regulators are no longer asking “Do you have AML policies?”
They are asking “Can you prove they work?”

Businesses that invest in risk-based frameworks, staff awareness, and inspection readiness will not only avoid penalties—but also build credibility with regulators and partners.

Categories
Uncategorized

Rising AML Fines in the UAE: How Businesses Can Avoid Penalties in 2026

AML enforcement in the UAE has entered a new phase. Regulators are no longer focused only on awareness and guidance—financial penalties, license suspensions, and public enforcement actions are rising sharply.

As the UAE strengthens its position as a global financial and investment hub, regulators are under increasing international pressure to demonstrate zero tolerance toward money laundering and terrorist financing. For businesses, this means one thing clearly: AML non-compliance in 2026 will be far more costly than ever before.

This article explains why AML fines are increasing in the UAE, which sectors face the highest risk, and how businesses can protect themselves from penalties.

Why Are AML Fines Increasing in the UAE?

Several forces are driving stricter enforcement and higher penalties:

  • Alignment with FATF recommendations

  • Increased scrutiny following global risk assessments

  • Rapid growth in high-risk sectors such as real estate, trade, and professional services

  • Use of advanced monitoring and supervisory tools by regulators

  • Shift from “education mode” to enforcement mode

Regulators now expect businesses to demonstrate active, documented, and risk-based AML compliance, not just policies on paper.

Why Real Estate Is a Primary AML Target

Real estate continues to attract close regulatory attention across the UAE—and globally.

Why criminals prefer real estate

Criminals are drawn to property transactions for several reasons:

  1. High transaction values
    Large sums can be moved or layered through a single deal.

  2. Lower historical controls compared to banks
    While improving, real estate has traditionally had fewer AML checkpoints.

  3. Complex ownership structures
    Shell companies, nominees, and third-party buyers make beneficial ownership harder to identify.

  4. Asset stability
    Once funds are converted into property, tracing or confiscation becomes more difficult.

In several countries, unchecked illicit investment has already distorted housing markets, pushing prices beyond the reach of ordinary citizens. This is why UAE authorities now expect strong AML controls from all real estate-related businesses.

What Is a Risk-Based Approach (RBA) and Why It Matters

A risk-based approach (RBA) is the foundation of modern AML enforcement.

Rather than applying identical checks to every client or transaction, businesses must:

  • Identify where money laundering risk is highest

  • Apply enhanced controls to high-risk situations

  • Use simplified measures only where justified

FATF guidelines clearly state that real estate agents, brokers, consultants, and related professionals must assess AML/CFT risk as part of daily operations.

Failure to implement a proper RBA is now one of the most common reasons for AML fines.

Common AML Failures That Lead to Penalties

Across enforcement actions, regulators repeatedly identify similar weaknesses:

  • Incomplete or outdated KYC files

  • Failure to identify the ultimate beneficial owner (UBO)

  • Poor source-of-funds verification

  • No transaction monitoring after onboarding

  • Lack of AML training for staff

  • Absence of internal AML policies or documented risk assessments

These gaps signal weak governance—and regulators are responding with significant fines.

Key AML Responsibilities Businesses Must Fulfill

To reduce penalty exposure, businesses—especially in real estate and professional services—must implement the following:

1. Robust KYC (Know Your Customer)

  • Verify buyer and seller identities

  • Identify the true owner of funds, even when intermediaries are involved

  • Keep records updated and accessible

2. Understand the Transaction

Ask critical questions:

  • Why is the client entering this transaction?

  • Is the structure unusually complex?

  • Is pricing significantly above or below market value?

These inconsistencies are common red flags.

3. Source of Funds Verification

  • Identify where the money originates

  • Flag cash-heavy transactions

  • Apply enhanced checks for offshore transfers or high-risk jurisdictions

4. Ongoing Monitoring

AML obligations do not end after onboarding.

  • Monitor changes in client behavior

  • Watch for unusual transaction patterns

  • Reassess risk periodically

Role of AML Consultants in Avoiding Penalties

Many UAE businesses now rely on external AML advisors to strengthen compliance frameworks.

Experienced AML consultants in the UAE help with:

  • Risk assessments and gap analysis

  • AML policy drafting

  • KYC and UBO review frameworks

  • Training programs

  • Regulatory readiness for inspections

Firms like Swenta, operating across audit, accounting, and compliance advisory, often support businesses in building AML systems that are practical, defensible, and regulator-ready.

Supervisors and Regulators: Stronger Oversight Than Ever

In the UAE, AML/CFT supervision 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, AMLD has:

  • Expanded sector coverage

  • Increased inspection frequency

  • Strengthened enforcement tools

  • Focused heavily on DNFBPs and real estate-linked businesses

As sectors mature, regulatory expectations rise. Where awareness is still developing, monitoring is stricter—not lighter.

Special Focus on Emerging and High-Risk Markets

Authorities pay close attention to:

  • Newly established agencies or firms

  • Businesses with limited AML experience

  • Regions with historically weak enforcement

  • Rapidly growing real estate developments

These areas require extra compliance vigilance to prevent exploitation.

Practical Steps to Reduce AML Penalty Risk in 2026

Businesses can take immediate action by:

  • Creating clear AML and KYC checklists

  • Using technology for transaction screening

  • Training staff regularly

  • Establishing escalation rules for high-risk cases

  • Conducting periodic internal AML reviews

  • Seeking guidance from AML advisors in the UAE

Prevention is significantly cheaper than penalties.

AML fines in the UAE are rising—and 2026 will mark a decisive shift toward tougher enforcement.

For businesses, compliance is no longer a checkbox exercise. It is a core risk management function tied directly to reputation, licensing, and financial stability.

Those who invest now in risk-based AML frameworks, staff training, and professional guidance will not only avoid penalties—but also gain trust with regulators, partners, and investors.

Categories
Uncategorized

UAE Salary Forecast 2026: Highest-Paying Roles and Sectors to Watch

he UAE job market is entering a new phase in 2026. Economic diversification, digital transformation, regulatory maturity, and global capital inflows are reshaping how companies hire—and how much they are willing to pay for the right talent.

For professionals planning their next career move and businesses budgeting for talent acquisition, understanding which roles and sectors will command premium salaries in 2026 is no longer optional—it’s strategic.

This guide breaks down the UAE salary forecast for 2026, highlighting the highest-paying roles, fastest-growing sectors, and key factors influencing compensation trends.

UAE Job Market Outlook for 2026

The UAE continues to strengthen its position as a global business hub. Several macro trends are driving salary growth:

  • Expansion of non-oil sectors

  • Increased foreign direct investment (FDI)

  • Corporate tax implementation and regulatory reforms

  • Demand for specialized, compliance-driven, and tech-enabled roles

  • Talent shortages in senior and niche positions

While average salary growth is expected to be moderate, top-tier and specialist roles are seeing disproportionately higher pay increases.

Top High-Paying Sectors in the UAE for 2026

1. Finance, Accounting & Tax Advisory

With the introduction of corporate tax, enhanced regulatory oversight, and growing complexity in financial reporting, finance professionals remain among the highest-paid talent in the UAE.

High-paying roles include:

  • Chief Financial Officer (CFO)

  • Finance Director

  • Corporate Tax Manager

  • International Tax Advisor

  • Risk & Compliance Head

Senior finance leaders with UAE regulatory knowledge and cross-border experience are expected to see salary increases of 10–20% in 2026.

Professional advisory firms like Swenta, operating across audit, accounting, and tax services, are seeing growing demand for experienced finance professionals who can combine technical expertise with strategic insight.

2. Technology & Digital Transformation

Technology continues to dominate salary growth across industries—not just within tech companies.

Highest-paying tech roles in 2026:

  • Chief Technology Officer (CTO)

  • AI & Data Science Lead

  • Cybersecurity Director

  • Cloud Solutions Architect

  • ERP & Digital Transformation Consultants

As companies invest heavily in automation, AI, and cybersecurity, senior tech talent remains scarce, pushing salaries higher—especially for professionals with leadership experience.

3. Legal, Compliance & Governance

Stronger regulation has increased demand for governance-focused professionals.

Top-paying roles include:

  • General Counsel

  • Head of Compliance

  • Corporate Governance Advisor

  • Regulatory Affairs Director

Professionals with UAE regulatory expertise, multinational exposure, and industry-specific knowledge command premium compensation, particularly in financial services, real estate, and large corporate groups.

4. Real Estate & Infrastructure Leadership

While mid-level roles remain stable, senior leadership positions in real estate continue to offer strong compensation due to large-scale developments and foreign investment.

High-paying roles include:

  • Real Estate Development Director

  • Asset Management Head

  • Project Finance Lead

  • Investment Strategy Director

Salaries at senior levels are driven by deal size, portfolio value, and strategic responsibility rather than volume-based activity.

5. Healthcare & Life Sciences

Healthcare expansion, medical tourism, and private investment are driving demand for skilled professionals.

Top-paying roles:

  • Hospital CEO / COO

  • Specialist Consultants

  • Healthcare Operations Directors

  • Medical Technology Executives

Senior management and specialist doctors are expected to see consistent salary growth into 2026.

Highest-Paying Job Roles in the UAE (2026 Forecast)

Across sectors, the highest salaries are concentrated at leadership and specialist levels:

  • Chief Executive Officer (CEO)

  • Chief Financial Officer (CFO)

  • Managing Director

  • Tax & Regulatory Heads

  • Technology & Data Leaders

  • Legal & Compliance Directors

What these roles share is decision-making authority, risk ownership, and strategic impact—not just technical skill.

Key Factors Influencing Salary Growth in 2026

1. Regulatory Complexity

New tax and compliance frameworks are pushing companies to pay more for expertise that reduces risk and ensures compliance.

2. Talent Shortages

Specialized skills—especially in tax, technology, and governance—remain in short supply.

3. Performance-Based Compensation

Variable pay, bonuses, and equity-linked incentives are becoming more common at senior levels.

4. Cross-Border Experience

Professionals with international exposure, especially across GCC, Europe, and Asia, command higher salaries.

What Employers Must Plan for in 2026

Companies need to:

  • Budget realistically for senior and specialist hires

  • Invest in retention to avoid rising replacement costs

  • Align salary structures with regulatory and business complexity

  • Benchmark compensation regularly

Advisory firms like Swenta often support businesses by aligning financial planning, workforce cost structuring, and compliance considerations—helping leadership teams make informed hiring decisions.

Career Strategy Tips for Professionals

If you’re planning your next move in 2026:

  • Upskill in regulatory, tax, or digital domains

  • Gain cross-functional exposure

  • Target leadership or advisory roles rather than execution-only positions

  • Build expertise that reduces business risk or drives strategic value

he UAE job market is entering a new phase in 2026. Economic diversification, digital transformation, regulatory maturity, and global capital inflows are reshaping how companies hire—and how much they are willing to pay for the right talent.

For professionals planning their next career move and businesses budgeting for talent acquisition, understanding which roles and sectors will command premium salaries in 2026 is no longer optional—it’s strategic.

This guide breaks down the UAE salary forecast for 2026, highlighting the highest-paying roles, fastest-growing sectors, and key factors influencing compensation trends.

UAE Job Market Outlook for 2026

The UAE continues to strengthen its position as a global business hub. Several macro trends are driving salary growth:

  • Expansion of non-oil sectors

  • Increased foreign direct investment (FDI)

  • Corporate tax implementation and regulatory reforms

  • Demand for specialized, compliance-driven, and tech-enabled roles

  • Talent shortages in senior and niche positions

While average salary growth is expected to be moderate, top-tier and specialist roles are seeing disproportionately higher pay increases.

Top High-Paying Sectors in the UAE for 2026

1. Finance, Accounting & Tax Advisory

With the introduction of corporate tax, enhanced regulatory oversight, and growing complexity in financial reporting, finance professionals remain among the highest-paid talent in the UAE.

High-paying roles include:

  • Chief Financial Officer (CFO)

  • Finance Director

  • Corporate Tax Manager

  • International Tax Advisor

  • Risk & Compliance Head

Senior finance leaders with UAE regulatory knowledge and cross-border experience are expected to see salary increases of 10–20% in 2026.

Professional advisory firms like Swenta, operating across audit, accounting, and tax services, are seeing growing demand for experienced finance professionals who can combine technical expertise with strategic insight.

2. Technology & Digital Transformation

Technology continues to dominate salary growth across industries—not just within tech companies.

Highest-paying tech roles in 2026:

  • Chief Technology Officer (CTO)

  • AI & Data Science Lead

  • Cybersecurity Director

  • Cloud Solutions Architect

  • ERP & Digital Transformation Consultants

As companies invest heavily in automation, AI, and cybersecurity, senior tech talent remains scarce, pushing salaries higher—especially for professionals with leadership experience.

3. Legal, Compliance & Governance

Stronger regulation has increased demand for governance-focused professionals.

Top-paying roles include:

  • General Counsel

  • Head of Compliance

  • Corporate Governance Advisor

  • Regulatory Affairs Director

Professionals with UAE regulatory expertise, multinational exposure, and industry-specific knowledge command premium compensation, particularly in financial services, real estate, and large corporate groups.

4. Real Estate & Infrastructure Leadership

While mid-level roles remain stable, senior leadership positions in real estate continue to offer strong compensation due to large-scale developments and foreign investment.

High-paying roles include:

  • Real Estate Development Director

  • Asset Management Head

  • Project Finance Lead

  • Investment Strategy Director

Salaries at senior levels are driven by deal size, portfolio value, and strategic responsibility rather than volume-based activity.

5. Healthcare & Life Sciences

Healthcare expansion, medical tourism, and private investment are driving demand for skilled professionals.

Top-paying roles:

  • Hospital CEO / COO

  • Specialist Consultants

  • Healthcare Operations Directors

  • Medical Technology Executives

Senior management and specialist doctors are expected to see consistent salary growth into 2026.

Highest-Paying Job Roles in the UAE (2026 Forecast)

Across sectors, the highest salaries are concentrated at leadership and specialist levels:

  • Chief Executive Officer (CEO)

  • Chief Financial Officer (CFO)

  • Managing Director

  • Tax & Regulatory Heads

  • Technology & Data Leaders

  • Legal & Compliance Directors

What these roles share is decision-making authority, risk ownership, and strategic impact—not just technical skill.

Key Factors Influencing Salary Growth in 2026

1. Regulatory Complexity

New tax and compliance frameworks are pushing companies to pay more for expertise that reduces risk and ensures compliance.

2. Talent Shortages

Specialized skills—especially in tax, technology, and governance—remain in short supply.

3. Performance-Based Compensation

Variable pay, bonuses, and equity-linked incentives are becoming more common at senior levels.

4. Cross-Border Experience

Professionals with international exposure, especially across GCC, Europe, and Asia, command higher salaries.

What Employers Must Plan for in 2026

Companies need to:

  • Budget realistically for senior and specialist hires

  • Invest in retention to avoid rising replacement costs

  • Align salary structures with regulatory and business complexity

  • Benchmark compensation regularly

Advisory firms like Swenta often support businesses by aligning financial planning, workforce cost structuring, and compliance considerations—helping leadership teams make informed hiring decisions.

Career Strategy Tips for Professionals

If you’re planning your next move in 2026:

  • Upskill in regulatory, tax, or digital domains

  • Gain cross-functional exposure

  • Target leadership or advisory roles rather than execution-only positions

  • Build expertise that reduces business risk or drives strategic value

The UAE salary forecast for 2026 points to one clear trend:
👉 Specialization, leadership, and regulatory expertise will be rewarded more than ever.

While average salary growth may remain steady, professionals and businesses operating at the intersection of finance, regulation, technology, and strategy will see the strongest gains.

For companies, the challenge is not just paying more—but paying smarter.

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Why AML Compliance Is Becoming a Board-Level Responsibility in UAE Companies

Anti-Money Laundering (AML) compliance in the UAE has undergone a fundamental shift. In 2025, AML is no longer viewed as a task handled only by compliance officers or risk teams. Instead, it has become a board-level responsibility, with directors and senior management expected to actively oversee, question, and guide AML frameworks.

Regulators are making it clear: when AML failures occur, accountability does not stop at the compliance department—it reaches the boardroom.

This article explains why AML governance has moved to the top of corporate agendas in the UAE and what boards must do to meet rising regulatory expectations.

The Changing AML Landscape in the UAE

Over the past few years, the UAE has significantly strengthened its AML/CFT framework to align with global standards set by the Financial Action Task Force (FATF). Enforcement actions, supervisory inspections, and regulatory guidance now emphasize governance, accountability, and effectiveness, not just policy existence.

As a result, boards are expected to:

  • Understand their company’s AML risk exposure

  • Approve and oversee AML frameworks

  • Ensure sufficient resources and authority for compliance functions

  • Be informed of material AML risks and incidents

AML failures are increasingly treated as corporate governance failures, not operational oversights.

Why Regulators Are Focusing on Boards and Senior Management

Criminal networks adapt quickly, exploiting weak oversight, poor controls, and fragmented decision-making. Regulators have learned that AML systems fail most often when:

  • Leadership is disengaged

  • Risk assessments are superficial

  • Compliance teams lack authority

  • Red flags are ignored due to commercial pressure

By placing responsibility at board level, regulators aim to ensure that business growth never overrides compliance obligations.

Why Certain Sectors—Including Real Estate—Remain High on the Risk Radar

While AML governance applies across all sectors, regulators continue to pay close attention to industries with higher exposure to financial crime.

Real estate remains a key example because:

  • Transactions involve high-value assets

  • Ownership structures can be layered or opaque

  • Third-party intermediaries are common

  • Once funds are invested in property, tracing becomes difficult

Globally, unchecked money laundering through real estate has inflated property prices, displaced local communities, and weakened financial integrity. These risks reinforce why boards must understand sector-specific AML exposure, not just generic compliance rules.

The Risk-Based Approach: A Governance Imperative

A risk-based approach (RBA) is the cornerstone of modern AML frameworks—and boards are ultimately responsible for ensuring it is applied correctly.

Rather than treating all clients and transactions equally, an RBA requires companies to:

  • Identify high-risk products, customers, and jurisdictions

  • Apply enhanced controls where risks are elevated

  • Allocate resources proportionately

  • Regularly review and update risk assessments

Boards must approve the risk appetite and ensure management can demonstrate how the RBA operates in practice—not just on paper.

Board Expectations Under FATF-Aligned Standards

Under FATF principles, senior management and boards are expected to:

  • Approve AML policies and risk assessments

  • Oversee the implementation of AML controls

  • Ensure independence of the compliance function

  • Receive regular AML reporting

  • Take corrective action when weaknesses are identified

In 2025, “lack of awareness” is no longer considered an acceptable defense.

Key AML Responsibilities Boards Can No Longer Delegate Away

1. Oversight of KYC and Beneficial Ownership Controls

Boards must ensure that management has robust processes to:

  • Verify customer identities

  • Identify ultimate beneficial owners (UBOs)

  • Detect nominee arrangements or shell companies

Weak KYC remains one of the most common causes of regulatory penalties.

2. Monitoring Source of Funds and Transaction Behavior

Following the money is a critical board-level concern. Red flags include:

  • Unexplained cash transactions

  • Payments from unrelated third parties

  • Offshore or high-risk jurisdiction involvement

  • Complex or illogical deal structures

Boards should receive summaries of material risks and suspicious activity trends—not just compliance statistics.

3. Ongoing Monitoring, Not One-Time Approval

AML compliance is continuous. Boards must ensure systems are in place for:

  • Ongoing transaction monitoring

  • Periodic client reviews

  • Escalation of unusual patterns

Approving a client relationship once is no longer sufficient.

Role of Supervisors and Regulators in Driving Board Accountability

In the UAE, AML/CFT supervision is overseen by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD), established under the Central Bank of the UAE.

Since 2020, AMLD has:

  • Expanded supervisory reach

  • Increased inspections across sectors

  • Focused on governance and control effectiveness

Regulators now assess whether boards actively engage with AML risks—or merely delegate them.

Special Attention on Emerging and Underdeveloped Markets

Markets or sectors with lower AML maturity receive enhanced scrutiny, particularly where:

  • New firms enter high-risk industries

  • AML awareness is limited

  • Internal controls are still developing

Boards operating in such environments must demonstrate stronger oversight and faster remediation of gaps.

How Boards Can Strengthen AML Governance in 2025

Practical steps boards should take include:

  • Reviewing and approving enterprise-wide AML risk assessments

  • Ensuring compliance teams have independence and authority

  • Requesting clear, risk-focused AML reporting

  • Supporting regular AML training for management

  • Engaging external AML advisors for independent reviews

Professional firms like Swenta, operating in audit, accounting, and compliance advisory, often support boards by providing independent AML assessments and governance-focused guidance without disrupting operations.

Why AML Is Now a Leadership Issue, Not Just a Compliance Issue

AML failures can lead to:

  • Regulatory penalties

  • Loss of banking relationships

  • Reputational damage

  • Business disruption

Boards that actively engage in AML governance protect not only compliance—but long-term business sustainability.

In 2025, AML compliance in the UAE has clearly moved into the boardroom. Regulators expect directors to understand risks, challenge assumptions, and ensure AML frameworks work in practice.

Companies whose boards treat AML as a strategic governance responsibility will be far better positioned to navigate regulatory scrutiny, maintain stakeholder trust, and grow sustainably.

Those that don’t risk learning this lesson the hard way.

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Top AML Priorities for UAE Businesses in 2025: Expert Insights for Compliance Teams

Anti-Money Laundering (AML) compliance in the UAE is entering a far more demanding phase in 2025. Regulators are no longer focused only on whether businesses have AML policies in place—they are assessing how effectively those policies work in practice.

With increased inspections, stricter enforcement, and closer alignment with FATF standards, UAE businesses across financial, non-financial, and professional sectors must reassess their AML priorities to avoid penalties, reputational damage, and operational disruption.

This guide outlines the key AML focus areas UAE businesses must address in 2025, based on regulatory expectations and evolving risk trends.

Why AML Compliance Is a Strategic Priority in 2025

AML is no longer a back-office function. In 2025, it directly affects:

  • Licensing and renewals

  • Banking relationships

  • Tender eligibility

  • Investor confidence

  • Cross-border transactions

Businesses that treat AML as a checklist risk regulatory action, while those that embed it into governance and operations gain long-term stability.

Why Certain Sectors—Including Real Estate—Remain High Risk

Criminal networks continue to exploit sectors where large transactions and complex ownership structures exist.

Real estate, in particular, remains vulnerable because:

  • Property transactions involve high-value transfers

  • Deals often include third parties or offshore entities

  • Asset ownership can be layered or concealed

  • Once funds enter property, tracing becomes difficult

Unchecked money laundering in real estate has distorted housing markets globally, pricing out residents and weakening trust in financial systems. As a result, UAE regulators maintain heightened scrutiny over this sector.

AML Priority #1: Strengthening the Risk-Based Approach (RBA)

A risk-based approach (RBA) is the foundation of AML compliance in the UAE.

Rather than applying identical checks to every client or transaction, businesses must:

  • Identify where money laundering or terrorist financing risks are highest

  • Allocate stronger controls to high-risk areas

  • Apply proportionate measures to lower-risk activities

FATF guidelines require all regulated entities to formally assess and document their AML risks—and regulators now expect evidence that RBAs are actively applied, not just written.

AML Priority #2: Enhanced KYC and Beneficial Ownership Verification

Know Your Customer (KYC) procedures remain one of the most closely reviewed AML controls.

In 2025, compliance teams must ensure they can:

  • Verify customer identity accurately

  • Identify the ultimate beneficial owner (UBO), not just nominees

  • Validate source of funds and source of wealth where required

  • Refresh KYC information periodically

Shell companies, proxies, and layered ownership structures are common red flags. Weak KYC is one of the most frequent causes of regulatory penalties.

AML Priority #3: Transaction Monitoring Beyond One-Time Checks

AML compliance does not end once onboarding is complete.

Businesses must implement ongoing monitoring, especially when dealing with repeat clients or long-term relationships. This includes:

  • Reviewing transaction patterns over time

  • Identifying sudden changes in behavior

  • Monitoring unusual pricing, payment routes, or deal structures

  • Escalating suspicious activity promptly

One-off checks are no longer sufficient under UAE AML expectations.

AML Priority #4: Source of Funds and Payment Transparency

Following the money remains a critical AML requirement.

Red flags that demand enhanced scrutiny include:

  • Cash-heavy transactions

  • Payments from unrelated third parties

  • Transfers from high-risk or offshore jurisdictions

  • Complex or unexplained payment chains

Compliance teams must be able to document how funds were generated, not just where they came from.

AML Priority #5: Sector-Specific Controls and Training

Different industries face different AML risks. In 2025, regulators expect controls tailored to business activity.

High-risk sectors such as real estate, DNFBPs, consultants, and professional service providers require:

  • Targeted AML training

  • Sector-specific red flag identification

  • Customized internal procedures

Generic AML manuals are increasingly viewed as inadequate.

AML Priority #6: Stronger Internal Governance and Accountability

AML compliance is now closely linked to corporate governance.

Key expectations include:

  • Clear AML reporting lines

  • Designated compliance officers with authority

  • Documented escalation and decision-making processes

  • Board or senior management oversight

Weak governance structures are often treated as systemic compliance failures.

Role of Supervisors and Regulators in the UAE

The UAE’s AML framework is overseen by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD), established under the Central Bank of the UAE.

Since 2020, AMLD has:

  • Expanded supervisory coverage across sectors

  • Increased inspections and enforcement actions

  • Issued guidance aligned with international standards

Sectors that are newer, fragmented, or rapidly growing receive closer attention, especially where AML maturity is still developing.

Special Focus on Emerging or Underdeveloped Markets

Markets with limited AML awareness or weak enforcement histories require enhanced oversight.

Supervisors focus on:

  • Newly established firms

  • Businesses entering high-risk sectors

  • Regions with limited compliance infrastructure

Strict monitoring helps prevent these markets from becoming safe havens for illicit activity.

Practical Steps UAE Businesses Should Take in 2025

To strengthen AML compliance effectively, businesses should:

  • Develop clear, documented risk assessments

  • Create practical due diligence checklists

  • Implement transaction monitoring tools

  • Conduct regular staff training

  • Review and test AML controls periodically

  • Seek expert AML advisory support when needed

Firms like Swenta, operating in audit and compliance advisory, often assist businesses in aligning AML frameworks with regulatory expectations—without overcomplicating operations.

In 2025, AML compliance in the UAE is no longer about avoiding fines—it is about protecting business continuity and credibility.

Organizations that prioritize risk-based controls, strong governance, and practical implementation will not only meet regulatory expectations but also strengthen trust with banks, partners, and regulators.

Those that delay action risk enforcement, reputational harm, and operational disruption.

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Why ICV Certification Is Essential for Business Growth and Compliance

In today’s competitive UAE business environment, growth is no longer driven by pricing alone. Government alignment, local value creation, and regulatory credibility now play a major role in winning contracts—especially in oil & gas, infrastructure, manufacturing, and government-linked sectors.

This is where ICV Certification (In-Country Value) becomes essential.

ICV is not just a compliance requirement. It is a strategic tool that directly impacts tender eligibility, contract awards, and long-term business sustainability in the UAE.

What Is ICV Certification in the UAE?

ICV Certification is part of the UAE’s national In-Country Value program, introduced to:

  • Strengthen the local economy

  • Increase Emirati employment

  • Encourage local procurement

  • Retain more value within the UAE

The certificate measures how much value a company contributes to the UAE economy through:

  • Local spending

  • Emirati workforce

  • Local assets

  • Manufacturing and operations inside the UAE

Businesses receive an ICV score, which is then used by government entities and major semi-government organizations during tender evaluations.

Why ICV Certification Matters More Than Ever in 2025

In 2025, ICV is no longer optional for many sectors. Companies without a valid ICV certificate often face:

  • Disqualification from tenders

  • Lower bid rankings

  • Reduced chances of long-term contracts

  • Missed partnership opportunities

Organizations such as ADNOC and other government-linked entities now prioritize suppliers with strong ICV scores, even when pricing is higher.

ICV Certification as a Growth Enabler

1. Increased Tender Success Rate

A strong ICV score directly improves tender rankings. In many evaluations, ICV carries equal or higher weight than price.

Businesses with competitive ICV scores often:

  • Win contracts over lower-priced competitors

  • Secure repeat contracts

  • Build preferred supplier status

2. Access to Government & Semi-Government Projects

ICV certification is mandatory or highly recommended for suppliers dealing with:

  • ADNOC Group companies

  • Government ministries

  • National infrastructure projects

  • Defense and manufacturing sectors

Without ICV, businesses are often excluded at the prequalification stage.

3. Stronger Local Market Position

ICV-certified companies are seen as:

  • Long-term contributors to the UAE economy

  • More stable and compliant partners

  • Better aligned with national development goals

This strengthens brand credibility and trust.

Compliance Benefits of ICV Certification

Beyond growth, ICV certification also supports financial and regulatory compliance.

1. Improved Financial Transparency

ICV calculations require:

  • Audited financial statements

  • Clear cost structures

  • Accurate payroll and asset records

This naturally strengthens internal financial controls.

2. Alignment With UAE Economic Policies

ICV supports broader UAE initiatives such as:

  • Economic diversification

  • Emiratization

  • Industrial development

  • Supply chain localization

Companies aligned with these goals face fewer regulatory and operational risks.

3. Audit-Ready Business Structure

Since ICV certificates are issued by approved certifying bodies, businesses must maintain:

  • Accurate documentation

  • Consistent reporting

  • Defensible financial data

Firms like Swenta, operating in audit and advisory services, often assist companies in preparing audit-ready financials for ICV certification without overexposure or misreporting.

Who Needs ICV Certification?

ICV certification is critical for:

  • Suppliers to ADNOC and group companies

  • Engineering & contracting firms

  • Manufacturers

  • Oil & gas service providers

  • Logistics and industrial service companies

  • SMEs aiming to scale into government projects

Even service-based businesses benefit as more tenders expand ICV requirements.

Key Components That Impact Your ICV Score

Your ICV score is influenced by:

  • Local procurement spending

  • Emirati employee salaries

  • Investment in UAE assets

  • Manufacturing inside the UAE

  • Revenue retained locally

Strategic planning can significantly improve these metrics over time.

Common ICV Mistakes Businesses Make

Many companies fail to maximize their ICV score due to:

  • Incorrect financial classification

  • Poor payroll structuring

  • Not planning Emiratization strategically

  • Delaying certification until tender deadlines

  • Treating ICV as a one-time compliance task

ICV should be treated as an ongoing business strategy, not a last-minute requirement.

How Businesses Can Improve Their ICV Score

Practical steps include:

  • Reviewing supplier sourcing strategies

  • Optimizing payroll and Emirati hiring plans

  • Structuring local investments efficiently

  • Maintaining clean, audited financial records

  • Conducting periodic ICV score simulations

Professional advisory support helps ensure improvements are compliant, sustainable, and defensible.

The Long-Term Impact of ICV Certification

Companies that approach ICV strategically experience:

  • Higher contract win rates

  • Better pricing power

  • Long-term government relationships

  • Stronger market positioning

  • Sustainable growth aligned with UAE Vision

In contrast, businesses that ignore ICV risk stagnation—even with strong technical capabilities.

ICV Certification is no longer just a requirement—it is a business growth lever in the UAE. As competition intensifies and government spending increasingly favors locally contributing companies, ICV becomes a deciding factor between growth and stagnation.

Businesses that invest early in ICV planning, supported by strong audit and financial frameworks, position themselves for long-term success in the UAE market.

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VAT on Mixed-Use Developments in the UAE: Everything Businesses Need to Know

Mixed-use developments have become a defining feature of the UAE’s real estate landscape. From integrated towers combining residential apartments, retail outlets, offices, and hospitality spaces to large-scale lifestyle communities, these projects offer strong commercial potential—but also complex VAT implications.

For developers, investors, property managers, and business owners, understanding VAT treatment on mixed-use developments in the UAE is critical to avoid costly errors, penalties, and denied input VAT recovery.

This guide explains how VAT applies to mixed-use developments, how to allocate costs correctly, and what businesses must do to stay compliant in 2025 and beyond.

What Is a Mixed-Use Development Under UAE VAT Law?

A mixed-use development is a property that includes both taxable and exempt components, such as:

  • Residential units (long-term residential use)

  • Commercial offices

  • Retail shops

  • Hotels or serviced apartments

  • Parking areas and common facilities

From a VAT perspective, these different uses do not receive the same tax treatment, which is why mixed-use projects require special attention.

Why VAT on Mixed-Use Developments Is Complex

The challenge arises because:

  • Residential leasing is generally VAT-exempt

  • Commercial leasing and retail sales are VAT-taxable at 5%

  • Shared construction and operational costs are often incurred together

This means businesses cannot automatically recover all VAT paid on expenses. Instead, VAT must be apportioned based on usage.

VAT Treatment of Different Components

1. Residential Units

  • Long-term residential leasing is VAT-exempt

  • No VAT charged on rent

  • Input VAT related solely to residential use is not recoverable

Note: Short-term accommodation (hotels, serviced apartments) is usually VAT-taxable

2. Commercial Units

  • Offices, shops, and retail outlets are standard-rated

  • VAT charged at 5%

  • Input VAT related to commercial units is recoverable

3. Common Areas & Shared Facilities

Examples include:

  • Lobbies

  • Elevators

  • Parking

  • Security

  • Landscaping

  • Central utilities

VAT on these costs must be allocated proportionally between taxable and exempt use.

Input VAT Apportionment: The Key Rule for Mixed-Use Projects

Under UAE VAT law, businesses must apply a fair and reasonable method to split input VAT between:

  • Recoverable VAT (commercial portion)

  • Non-recoverable VAT (residential portion)

Common apportionment methods include:

  • Floor area ratio

  • Revenue-based allocation

  • Usage-based allocation

The chosen method must be:

  • Consistent

  • Documented

  • Defensible during FTA audits

VAT During Construction Phase

During construction, most expenses relate to both residential and commercial components, such as:

  • Contractor invoices

  • Consultant fees

  • Infrastructure and utilities

  • Project management costs

Businesses must:

  • Track costs carefully

  • Apply provisional VAT recovery

  • Adjust VAT once actual usage becomes clear

Failure to plan VAT recovery during construction can lead to permanent VAT loss.

VAT on Sale of Mixed-Use Properties

Residential Sales

  • First supply of residential buildings within 3 years may be zero-rated

  • Subsequent sales are usually VAT-exempt

Commercial Sales

  • Subject to 5% VAT

  • Buyer may apply reverse charge rules if eligible

Each transaction must be reviewed individually.

VAT Compliance Risks for Mixed-Use Developments

Common issues identified by the FTA include:

  • Incorrect VAT classification

  • Overclaiming input VAT

  • Poor documentation

  • No formal apportionment policy

  • Inconsistent VAT treatment across returns

These errors often result in:

  • VAT assessments

  • Administrative penalties

  • Blocked VAT refunds

  • Retrospective adjustments

Best Practices for VAT Compliance in 2025

To stay compliant, businesses should:

  • Create a clear VAT mapping for each unit

  • Maintain separate cost tracking

  • Document VAT apportionment logic

  • Review VAT positions annually

  • Reassess VAT treatment when usage changes

  • Conduct periodic VAT health checks

Professional VAT advisors, including audit and tax firms like Swenta, often support developers and property owners in reviewing VAT structures and ensuring compliance with evolving FTA expectations.

Impact of Increased VAT Scrutiny in 2025

In 2025, the UAE Federal Tax Authority has intensified:

  • Data analytics

  • Cross-checking of property records

  • VAT audits on real estate projects

Mixed-use developments are a high-focus area due to the complexity and high transaction values involved.

VAT on mixed-use developments in the UAE requires careful planning, accurate cost allocation, and strong documentation. With different VAT treatments applying to residential and commercial components, even small errors can lead to significant financial exposure.

As enforcement tightens in 2025, businesses involved in mixed-use developments must move beyond basic VAT compliance and adopt a structured, well-documented VAT strategy to protect cash flow and avoid penalties.

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How to Calculate VAT in Dubai: An Easy Step-by-Step Guide

Value Added Tax (VAT) has been part of the UAE’s tax system since 2018, yet many individuals and businesses in Dubai still find VAT calculations confusing. Whether you are a small business owner, freelancer, startup founder, or finance professional, understanding how to calculate VAT correctly is essential to avoid penalties and ensure compliance.

This guide explains VAT calculation in Dubai in simple terms, with clear steps, practical examples, and common mistakes to avoid—fully updated for 2025 compliance expectations.

What Is VAT in Dubai?

VAT (Value Added Tax) is an indirect tax charged on the supply of goods and services at each stage of the supply chain. In the UAE:

  • The standard VAT rate is 5%

  • VAT applies to most goods and services unless specifically exempt or zero-rated

  • VAT is governed by the Federal Tax Authority (FTA)

Businesses act as VAT collectors, charging VAT to customers and remitting it to the FTA.

Who Needs to Calculate VAT in Dubai?

You must calculate VAT if you are:

  • A VAT-registered business

  • Required to register due to turnover exceeding AED 375,000

  • Voluntarily registered (turnover above AED 187,500)

  • Issuing tax invoices or filing VAT returns

  • Claiming input VAT refunds

Even non-registered businesses should understand VAT to price products correctly.

Basic VAT Formula Used in Dubai

The VAT calculation formula is straightforward:

VAT Amount = Taxable Value × 5%

Total Price Including VAT = Taxable Value + VAT

Step-by-Step: How to Calculate VAT in Dubai

Step 1: Identify Whether VAT Applies

First, confirm the VAT status of the transaction:

  • Standard-rated (5%) – Most goods and services

  • Zero-rated (0%) – Exports, international transport, some healthcare and education

  • Exempt – Residential rent, bare land, certain financial services

VAT calculation applies only to taxable supplies.

Step 2: Determine the Taxable Value

The taxable value usually includes:

  • Price of goods or services

  • Additional charges (delivery, packaging, service fees)

  • Any expenses charged to the customer

Discounts given before invoicing reduce the taxable value.

Step 3: Apply the 5% VAT Rate

Multiply the taxable value by 5%.

Example:

  • Service value: AED 10,000

  • VAT (5%): AED 500

  • Total invoice value: AED 10,500

Step 4: Issue a VAT-Compliant Tax Invoice

A valid tax invoice must include:

  • VAT registration number

  • Invoice date and number

  • Customer details

  • Taxable amount

  • VAT amount

  • Total including VAT

Incorrect invoices can result in penalties.

Step 5: Record VAT for Filing

VAT charged to customers = Output VAT
VAT paid on expenses = Input VAT

The difference determines:

  • VAT payable to FTA

  • OR VAT refundable

How to Calculate VAT Backwards (VAT Inclusive Price)

Sometimes prices already include VAT.

VAT Amount = (Total Price × 5) ÷ 105

Example:

  • Price including VAT: AED 1,050

  • VAT = (1,050 × 5) ÷ 105 = AED 50

  • Net value = AED 1,000

This method is essential for audits and reconciliations.

VAT Calculation for Businesses: Output vs Input VAT

Output VAT

  • VAT collected from customers

  • Declared in VAT return

Input VAT

  • VAT paid on business expenses

  • Can be recovered if expenses are VAT-eligible

Net VAT Payable

Output VAT − Input VAT

Common VAT Calculation Mistakes in Dubai

Many businesses make avoidable errors such as:

  • Charging VAT on exempt supplies

  • Missing VAT on additional charges

  • Incorrect VAT treatment of mixed supplies

  • Claiming ineligible input VAT

  • Using wrong VAT percentage

  • Poor documentation

These mistakes often lead to FTA penalties and audits.

VAT Calculation for Different Business Types

Retail & Trading Businesses

  • VAT charged at point of sale

  • Inventory and pricing must factor VAT

Service Providers

  • VAT applied on invoice date or payment date (earliest)

Real Estate & Construction

  • VAT treatment depends on residential vs commercial use

  • Mixed-use developments require careful allocation

Freelancers & Consultants

  • VAT applies if registered

  • Professional services are usually standard-rated

Why Accurate VAT Calculation Matters in 2025

In 2025, the FTA has increased:

  • Data analytics

  • Cross-checking of returns

  • Penalties for repeated errors

Incorrect VAT calculations can lead to:

  • Financial penalties

  • Blocked VAT refunds

  • Reputational damage

  • Cash-flow disruption

How Professional Support Simplifies VAT Compliance

Many businesses rely on professional advisors to:

  • Set up VAT systems

  • Review VAT calculations

  • Prepare VAT returns

  • Handle FTA audits

  • Correct historical VAT errors

Firms like Swenta, operating in Dubai’s audit and tax advisory space, assist businesses in maintaining accurate VAT records and calculations while staying compliant with evolving regulations.

Best Practices for Easy VAT Calculation

  • Use VAT-enabled accounting software

  • Reconcile VAT monthly

  • Maintain proper invoices

  • Separate VAT and non-VAT income

  • Review VAT treatment regularly

  • Seek expert review for complex transactions

Calculating VAT in Dubai does not need to be complicated. By understanding the VAT rate, applying the correct formula, and maintaining proper records, businesses and individuals can stay compliant and avoid costly errors.

As VAT enforcement tightens in 2025, accurate calculation is no longer optional—it is essential. Whether you manage VAT in-house or with expert assistance, staying informed ensures smooth operations and financial confidence.

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The Growing Link Between AML & Corporate Governance in UAE 2025

In 2025, Anti-Money Laundering (AML) compliance is no longer treated as a standalone regulatory obligation. Across the UAE, regulators, investors, and financial institutions increasingly view AML as a core pillar of corporate governance.

Strong governance frameworks now depend on how effectively a company identifies financial crime risks, applies internal controls, and holds leadership accountable. Businesses that fail to integrate AML into their governance structures face not only penalties—but long-term damage to credibility, banking access, and enterprise value.

This article explains why AML and corporate governance are converging, why real estate remains a high-risk focus area, and how UAE businesses can strengthen governance through a risk-based AML approach.

Why AML Has Become a Governance Issue in 2025

Historically, AML compliance was treated as an operational or compliance department responsibility. Today, regulators expect board-level oversight and executive accountability.

Key reasons for this shift include:

  • Increased complexity of financial crime

  • Cross-border ownership and transactions

  • Use of shell companies and nominee structures

  • Global enforcement pressure driven by FATF standards

  • Investor demand for transparency and ethical conduct

As a result, AML failures are now viewed as governance failures, not administrative oversights.

Corporate Governance and AML: How They Intersect

Corporate governance focuses on how a company is directed, controlled, and monitored. AML supports governance by ensuring:

  • Transparency in ownership and transactions

  • Ethical business conduct

  • Risk awareness at leadership level

  • Accountability through documented controls

  • Protection of stakeholder interests

A weak AML framework signals poor governance, regardless of profitability.

Why Real Estate Is Closely Linked to Governance Risk

Real estate continues to attract heightened regulatory attention due to its governance vulnerabilities.

Why Is Real Estate Targeted?

Criminals are drawn to real estate transactions for several reasons:

  1. High-value transactions
    A single deal can move large sums of illicit funds.

  2. Lower historical oversight compared to banks
    This creates gaps criminals can exploit.

  3. Opaque ownership structures
    Properties are often purchased through shell companies or third parties, masking the true owner.

  4. Asset-based laundering
    Once funds are converted into property, tracing or seizure becomes more difficult.

In multiple jurisdictions, unchecked money laundering has distorted housing markets, reduced affordability, and weakened public trust. These impacts highlight why AML failures in real estate are also governance failures affecting communities and markets.

The Risk-Based Approach (RBA): A Governance Tool

A risk-based approach (RBA) lies at the heart of modern AML and corporate governance.

Instead of applying uniform checks across all transactions, businesses:

  • Identify higher-risk activities

  • Allocate stronger controls to those areas

  • Apply simplified measures where risk is lower

According to FATF guidance, every country and regulated entity must embed RBA into its AML framework.

For leadership teams, RBA demonstrates:

  • Risk awareness

  • Proportionate decision-making

  • Effective oversight

  • Responsible use of resources

AML consultants in Dubai often support boards and senior management in implementing RBAs that align compliance with governance objectives.

Key AML Responsibilities That Strengthen Governance

1. Know Your Customer (KYC)

KYC is foundational to governance transparency.

Businesses must:

  • Verify buyer and seller identities

  • Identify ultimate beneficial owners (UBOs)

  • Confirm authority of representatives

Failure to establish true ownership weakens board-level risk visibility.

2. Understanding the Transaction

Governance requires understanding why transactions occur.

Red flags include:

  • Unusually complex deal structures

  • Prices significantly above or below market value

  • Transactions inconsistent with the client’s profile

Boards and compliance leaders are expected to question and challenge such anomalies.

3. Source of Funds Verification

Tracing the origin of funds supports both AML and ethical governance.

Higher scrutiny is required when:

  • Cash is involved

  • Offshore accounts are used

  • Funds originate from high-risk jurisdictions

Lack of clarity here exposes companies to enforcement and reputational harm.

4. Ongoing Monitoring and Oversight

Good governance is continuous, not transactional.

Organizations must:

  • Monitor repeat clients

  • Track behavioral changes

  • Reassess risk periodically

Static AML programs signal weak oversight.

Role of AML Consultants in Governance Alignment

Many organizations struggle to translate regulatory AML requirements into practical governance controls.

Professional AML advisors in the UAE help businesses by:

  • Conducting AML and governance risk assessments

  • Aligning AML frameworks with board oversight

  • Drafting governance-linked AML policies

  • Supporting goAML reporting and internal audits

  • Training leadership and compliance teams

Firms like Swenta assist companies in embedding AML into governance structures without disrupting operations or growth strategies.

Regulatory Oversight and Governance Expectations

Who Oversees AML Compliance in the UAE?

The Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD) operates under the Central Bank of the UAE (CBUAE).

Since 2020, AMLD has:

  • Expanded sector coverage

  • Increased inspections

  • Strengthened enforcement actions

Regulators now assess not only technical compliance but also governance effectiveness—including leadership involvement and internal accountability.

Special Focus on Emerging and Weakly Regulated Markets

Governance risks are higher in markets that are:

  • Newly developing

  • Lightly regulated

  • Lacking AML awareness

Supervisors pay closer attention to:

  • New market entrants

  • Inexperienced management teams

  • Regions with weak enforcement histories

Until maturity improves, intensive monitoring remains necessary to prevent abuse.

Practical Governance-Focused AML Measures for 2025

Businesses can strengthen both AML and governance by:

  • Assigning AML accountability at senior management level

  • Maintaining clear due diligence checklists

  • Using technology for screening and monitoring

  • Conducting regular AML gap assessments

  • Training staff and leadership consistently

  • Engaging external AML advisors when needed

Documented decision-making is key to governance defensibility.

Why AML Is Now a Board-Level Priority

In 2025, strong AML frameworks deliver more than compliance:

  • Improved investor confidence

  • Better access to banking and financing

  • Reduced enforcement exposure

  • Enhanced corporate reputation

  • Long-term business sustainability

Companies that integrate AML into governance are better positioned to grow responsibly in the UAE’s regulated environment.

The link between AML and corporate governance in the UAE has never been stronger. Regulators now expect businesses to treat AML as a leadership responsibility, not a procedural task.

By embedding a risk-based AML approach, strengthening KYC controls, and ensuring ongoing oversight, organizations can protect themselves from financial crime while reinforcing ethical governance standards.

Advisory firms such as Swenta support UAE businesses in aligning AML compliance with modern governance expectations—helping leadership teams stay compliant, credible, and future-ready.

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AML Checks Explained: Compliance Requirements, KYC Processes, and Risk Assessment

Anti-Money Laundering (AML) checks have become a critical compliance obligation for businesses operating in the UAE and globally. In 2025, regulators expect companies not only to perform basic identity checks but to actively assess risk, monitor transactions, and demonstrate control effectiveness.

From real estate firms and consultants to trading companies and corporate service providers, AML checks now form the backbone of legal compliance, financial integrity, and corporate governance.

This guide explains AML compliance requirements, how KYC processes work, the importance of risk assessment, and what businesses must do to remain compliant in 2025.

What Are AML Checks?

AML checks are a set of controls designed to prevent criminals from using legitimate businesses to launder money or finance terrorism. These checks help organizations:

  • Verify customer identity

  • Understand ownership structures

  • Assess money laundering risks

  • Detect suspicious activity

  • Report concerns to authorities

AML checks are not a one-time task. They must be continuous, risk-based, and well-documented.

Why AML Checks Matter More in 2025

Regulatory expectations have increased due to:

  • Cross-border financial crime

  • Use of shell companies and nominees

  • Digital transactions and remote onboarding

  • FATF-driven enforcement pressure

Businesses that fail to implement proper AML checks risk:

  • Financial penalties

  • License suspension

  • Criminal liability

  • Loss of banking relationships

  • Long-term reputational damage

Why Real Estate Is a High-Risk Sector

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

Why Is Real Estate Targeted by Criminals?

Criminals often prefer real estate transactions because:

  1. High transaction values
    Large sums of money can be moved through a single deal.

  2. Lower historical regulation than banks
    This creates opportunities to bypass strict financial controls.

  3. Hidden ownership structures
    Shell companies, third-party buyers, and nominee arrangements can disguise the true owner.

  4. Asset conversion advantage
    Once money is invested in property, tracing or recovering illicit funds becomes more difficult.

In some countries, unchecked real estate laundering has distorted property prices, affected housing affordability, and damaged public trust. The consequences extend far beyond paperwork.

Core AML Compliance Requirements

AML compliance obligations vary by sector but generally include:

  • Customer Due Diligence (CDD)

  • Enhanced Due Diligence (EDD) for high-risk cases

  • Ultimate Beneficial Ownership (UBO) verification

  • Risk assessments

  • Ongoing monitoring

  • Suspicious Transaction Reporting (STR)

  • Record retention

  • AML policies and internal controls

  • Staff training

Regulators expect evidence-based compliance, not generic templates.

Understanding KYC (Know Your Customer) Processes

KYC is the foundation of AML compliance.

What Is KYC?

KYC refers to the process of verifying and understanding a client’s identity, ownership structure, and risk profile before and during a business relationship.

Key Elements of KYC

1. Identity Verification

  • Government-issued ID for individuals

  • Trade licenses and incorporation documents for entities

2. Beneficial Ownership Identification

  • Identify the natural person who ultimately owns or controls the entity

  • Look beyond legal shareholders

3. Purpose and Nature of Relationship

  • Why is the client engaging in the transaction?

  • Does it align with their profile and business activity?

4. Risk Profiling

  • Client type

  • Country of origin

  • Transaction value

  • Industry risk

KYC must be risk-based, not checkbox-driven.

What Is a Risk-Based Approach (RBA)?

A risk-based approach (RBA) focuses compliance resources where risks are highest.

Instead of applying the same checks to every client, businesses:

  • Identify higher-risk scenarios

  • Apply stronger controls to those cases

  • Use simplified checks for lower-risk relationships

FATF guidelines require all countries—and regulated businesses—to adopt this approach.

AML consultants in Dubai often help organizations design and implement practical RBAs aligned with regulatory expectations.

Key AML Steps for Real Estate Professionals

To apply an effective RBA, real estate professionals must follow structured AML checks.

1. Perform Robust KYC

Always verify:

  • Buyer and seller identities

  • Ultimate beneficial owners

  • Authority of representatives

Nominee or proxy arrangements require enhanced scrutiny.

2. Understand the Transaction

Ask critical questions:

  • Why is the property being bought or sold?

  • Is the deal unusually complex?

  • Does the price align with market norms?

Unusual structures or unexplained pricing gaps are warning signs.

3. Follow the Source of Funds

Understanding where the money comes from is essential:

  • Cash-heavy transactions

  • Offshore or high-risk jurisdictions

  • Multiple layered transfers

Such scenarios trigger Enhanced Due Diligence (EDD).

4. Monitor Ongoing Relationships

AML does not end after onboarding:

  • Monitor repeat clients

  • Watch for behavioral changes

  • Update risk profiles regularly

Continuous monitoring is a regulatory expectation.

Role of AML Consultants in the UAE

Implementing AML checks internally can be complex, especially for non-financial businesses.

AML advisors support organizations by:

  • Conducting AML risk assessments

  • Designing KYC and RBA frameworks

  • Drafting AML policies and procedures

  • Supporting goAML reporting

  • Training employees

  • Performing AML audits and gap assessments

Firms like Swenta assist businesses in building practical, regulator-ready AML frameworks that align with UAE laws without disrupting operations.

Supervisory Oversight and Enforcement

Who Regulates AML Compliance in the UAE?

The primary authority is the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD).

  • Operates under the Central Bank of the UAE (CBUAE)

  • Supervises AML compliance across multiple sectors

  • Conducts inspections and enforcement actions

Since 2020, enforcement activity has increased significantly, especially for DNFBPs and high-risk sectors.

Special Focus on Emerging and Weakly Regulated Markets

In developing or under-regulated sectors, authorities apply additional scrutiny.

Supervisors closely monitor:

  • Newly established firms

  • Businesses with limited AML awareness

  • Regions with weak enforcement histories

Until maturity improves, strict monitoring remains essential to prevent misuse.

Practical AML Implementation Tips for 2025

To strengthen AML checks, businesses should:

  • Maintain clear KYC and due diligence checklists

  • Use technology for screening and monitoring

  • Train staff regularly

  • Define escalation procedures for high-risk cases

  • Conduct periodic AML gap assessments

  • Seek professional AML advisory support

Documentation, consistency, and governance are key.

Why AML Checks Are a Strategic Priority

Strong AML frameworks:

  • Protect businesses from financial crime exposure

  • Improve credibility with banks and regulators

  • Support sustainable growth

  • Strengthen corporate governance

In 2025, AML compliance is no longer optional—it is a business survival requirement.

AML checks in the UAE now go far beyond basic KYC. Regulators expect businesses to demonstrate active risk assessment, continuous monitoring, and strong internal controls.

Understanding AML compliance requirements, implementing a risk-based approach, and strengthening KYC processes are essential for operating safely and legally in today’s environment.

Professional advisory firms such as Swenta help businesses navigate AML obligations with clarity and confidence—ensuring compliance without compromising growth.

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UAE AML Regulations Explained: Key Laws, Compliance Obligations, and Enforcement

Anti-Money Laundering (AML) regulations in the UAE have evolved significantly over the last few years. In 2025, compliance is no longer a formality—it is a core legal and governance requirement for businesses operating in the country.

Driven by global standards, FATF expectations, and increased enforcement activity, UAE AML regulations now affect a wide range of sectors including real estate, corporate service providers, professional consultants, trading companies, and financial institutions.

This guide explains the key AML laws in the UAE, compliance obligations for businesses, enforcement mechanisms, and practical steps to stay compliant.

Overview of AML Regulations in the UAE

The UAE has adopted a robust AML/CFT framework aligned with international best practices. The regulatory focus is on preventing:

  • Money laundering

  • Terrorist financing

  • Proceeds of crime entering the UAE economy

Businesses are expected not only to follow written rules but to demonstrate active, risk-based compliance.

Failure to comply can lead to:

  • Heavy financial penalties

  • License suspension or cancellation

  • Criminal liability

  • Long-term reputational damage

Key UAE AML/CFT Laws and Legal Framework

UAE AML compliance is built around several core laws and regulations:

Federal AML/CFT Law

This law establishes:

  • Criminal offenses related to money laundering and terrorism financing

  • Obligations for reporting entities

  • Penalties for non-compliance

Cabinet Decisions & Executive Regulations

These clarify:

  • Customer Due Diligence (CDD) requirements

  • Record-keeping obligations

  • Suspicious Transaction Reporting (STR) rules

  • Risk-based compliance expectations

FATF Alignment

The UAE’s AML regime closely follows Financial Action Task Force (FATF) recommendations, particularly around:

  • Risk-based supervision

  • Beneficial ownership transparency

  • DNFBP oversight

Why Real Estate Is a High-Risk Sector

Among all non-financial sectors, real estate receives heightened AML scrutiny.

Why Is Real Estate Targeted by Criminals?

Criminals favor real estate for several reasons:

  1. High transaction values
    Large sums can be moved through a single purchase.

  2. Lower controls compared to banks
    Historically, fewer transaction-monitoring mechanisms existed.

  3. Opaque ownership structures
    Use of shell companies, nominees, or third parties can hide the real owner.

  4. Asset conversion advantage
    Once funds are invested in property, tracing or recovering them becomes more difficult.

In some countries, unchecked money laundering through property markets has distorted prices, harming ordinary citizens and urban stability. The impact goes far beyond paperwork—it affects society and governance.

Risk-Based Approach (RBA): The Foundation of UAE AML Compliance

Modern UAE AML regulations are built on a risk-based approach (RBA).

What Is a Risk-Based Approach?

An RBA requires businesses to:

  • Identify money laundering and terrorist financing risks

  • Assess client, transaction, geographic, and sector risks

  • Apply enhanced controls for higher-risk cases

  • Use simplified measures for lower-risk scenarios

Instead of treating all transactions equally, resources are focused where risks are highest.

FATF guidelines require real estate agents, brokers, and professional service providers to actively assess risk levels—not just follow checklists.

Core AML Compliance Obligations for Businesses

Depending on the sector, businesses in the UAE must comply with the following obligations:

  • Customer Due Diligence (CDD)

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

  • Ultimate Beneficial Owner (UBO) identification

  • Ongoing transaction monitoring

  • Suspicious Transaction Reporting (STR)

  • Record retention

  • AML governance and internal controls

  • Staff training

AML compliance is not a one-time exercise—it is continuous and dynamic.

Key AML Steps for Real Estate Professionals

To implement an effective RBA, real estate professionals must take specific steps:

1. Know Your Customer (KYC)

  • Verify buyer and seller identities

  • Identify the true beneficial owner of funds

  • Validate documents and ownership structures

KYC must reflect the actual risk profile, not just basic identification.

2. Understand the Transaction

Businesses should assess:

  • The purpose of the transaction

  • Whether the structure is unnecessarily complex

  • Whether pricing aligns with market norms

Unusual complexity or unexplained pricing gaps are red flags.

3. Follow the Money

Understanding the source of funds is critical:

  • Cash-heavy transactions

  • Offshore or high-risk jurisdictions

  • Multiple layered transfers

Such cases require enhanced due diligence.

4. Ongoing Monitoring

AML obligations continue beyond onboarding:

  • Monitor recurring clients

  • Watch for behavioral or transaction pattern changes

  • Update risk assessments periodically

Role of AML Consultants in the UAE

Implementing AML requirements internally can be challenging—especially for non-financial businesses.

AML consultants in the UAE help by:

  • Conducting AML risk assessments

  • Designing RBA frameworks

  • Drafting AML policies and procedures

  • Supporting goAML registration and reporting

  • Training employees

  • Performing independent AML audits and gap assessments

Firms like Swenta support businesses by translating regulatory expectations into practical, business-friendly compliance frameworks.

Supervision and Enforcement in the UAE

Who Enforces AML Compliance?

The main supervisory authority is the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD).

  • Operates under the Central Bank of the UAE (CBUAE)

  • Supervises AML compliance across multiple sectors

  • Conducts inspections, issues guidance, and enforces penalties

Since 2020, enforcement activity has increased significantly, with a strong focus on DNFBPs and emerging sectors.

Special Focus on Emerging and Weakly Regulated Markets

In developing or under-regulated sectors, authorities apply additional scrutiny.

Supervisors pay close attention to:

  • Newly established firms

  • Businesses with low AML awareness

  • Sectors with historical compliance gaps

Until maturity improves, strict monitoring remains essential to prevent misuse.

Practical AML Implementation Tips for 2025

To strengthen AML compliance, businesses should:

  • Maintain clear due diligence checklists

  • Use technology for screening and monitoring

  • Train staff regularly

  • Define escalation procedures for high-risk cases

  • Conduct periodic AML gap assessments

  • Seek professional AML advisory support when needed

Consistency and documentation are key.

Why AML Compliance Matters Beyond Penalties

Strong AML frameworks:

  • Protect businesses from financial crime exposure

  • Improve credibility with banks and partners

  • Reduce regulatory and reputational risk

  • Support long-term sustainability

In 2025, AML compliance is no longer just legal—it is strategic governance.

UAE AML regulations have entered a phase of active enforcement and accountability. Businesses that fail to adapt risk serious consequences, while those that implement structured, risk-based compliance gain stability and trust.

Understanding key AML laws, adopting a risk-based approach, and strengthening internal controls are essential steps for every UAE business today.

Professional advisory firms such as Swenta assist organizations in navigating AML regulations with clarity, accuracy, and confidence—ensuring compliance without disrupting growth.

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Anti-Money Laundering (AML) Compliance Services in Dubai: A Complete Business Guide (2025)

Anti-Money Laundering (AML) compliance has become a critical business obligation in Dubai and across the UAE. With increasing regulatory scrutiny, cross-border transactions, and global pressure from FATF, businesses operating in the UAE must ensure their AML frameworks are not only compliant—but effective.

In 2025, AML compliance is no longer limited to banks. Real estate firms, corporate service providers, consultants, traders, and professional service firms are now firmly within the regulatory spotlight. This guide explains AML compliance services in Dubai, why they matter, and how businesses can stay compliant in a rapidly evolving regulatory environment.

Understanding AML Compliance in Dubai

AML compliance refers to the systems, controls, and procedures businesses must implement to prevent:

  • Money laundering

  • Terrorist financing

  • Proceeds of crime entering the financial system

In Dubai, AML obligations are governed by federal AML/CFT laws, FATF-aligned regulations, and supervision by designated authorities. Failure to comply can result in heavy penalties, license suspension, reputational damage, and criminal liability.

Professional AML compliance services help businesses design, implement, and maintain compliant frameworks tailored to their risk profile.

Why Certain Sectors Face Higher AML Risk

Regulators do not treat all industries equally. Some sectors are inherently more exposed to financial crime—and real estate is one of the most closely monitored.

Why Is Real Estate Targeted?

Criminals often prefer real estate for several reasons:

  1. High-value transactions
    Property purchases allow large sums of money to move in a single deal.

  2. Lower regulatory intensity than banking
    Compared to banks, real estate transactions may involve fewer real-time controls.

  3. Complex ownership structures
    Shell companies, nominees, and third parties can hide the real owner of funds.

  4. Difficulty in tracing funds post-investment
    Once money is converted into property, it becomes harder to track or confiscate.

In some jurisdictions, unchecked money laundering through real estate has driven property prices beyond the reach of ordinary citizens. The impact is not just financial—it affects communities, governance, and trust in the system.

The Risk-Based Approach (RBA): The Core of AML Compliance

Modern AML compliance is built around a risk-based approach (RBA).

Instead of applying the same level of checks to every client and transaction, businesses must focus resources on higher-risk areas.

What Is a Risk-Based Approach?

An RBA requires businesses to:

  • Identify money laundering and terrorist financing risks

  • Assess the level of risk for clients, transactions, and geographies

  • Apply enhanced controls where risk is higher

  • Use simplified measures where risk is demonstrably low

FATF guidelines require countries—and businesses—to adopt this approach across all regulated sectors.

Key AML Obligations for Businesses in Dubai

Depending on the nature of operations, businesses may be classified as DNFBPs (Designated Non-Financial Businesses and Professions) or regulated entities. Common AML obligations include:

  • Customer Due Diligence (CDD)

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

  • Ongoing transaction monitoring

  • Suspicious Transaction Reporting (STR)

  • Record keeping

  • AML training and governance

AML compliance services in Dubai help businesses meet these obligations efficiently and consistently.

Key AML Steps for Real Estate and High-Risk Businesses

To implement an effective RBA, businesses—especially in real estate—must focus on the following areas:

1. Know Your Customer (KYC)

  • Verify the identity of buyers and sellers

  • Identify the ultimate beneficial owner (UBO)

  • Validate documents and source information

KYC must go beyond basic identity checks and reflect the client’s risk profile.

2. Understand the Transaction

Businesses should assess:

  • The purpose of the transaction

  • Whether the structure is unusually complex

  • Whether pricing aligns with market value

Unusual complexity or unexplained deviations are red flags.

3. Source of Funds & Source of Wealth

A critical AML requirement is understanding where the money comes from:

  • Cash-heavy transactions

  • Offshore transfers

  • Funds routed through multiple jurisdictions

These scenarios require enhanced scrutiny.

4. Ongoing Monitoring

AML is not a one-time exercise.

Businesses must monitor:

  • Repeat clients

  • Changes in transaction patterns

  • Behaviour inconsistent with client profile

This is especially important for long-term client relationships.

Role of AML Consultants in Dubai

AML consultants play a practical role in helping businesses move from theory to implementation.

Typical AML compliance services include:

  • AML risk assessments

  • Policy and procedure development

  • RBA framework design

  • KYC and EDD process setup

  • goAML registration and reporting support

  • AML training for staff

  • Independent AML audits and gap assessments

Firms such as Swenta support businesses by aligning AML frameworks with UAE regulations while keeping operations practical and business-friendly.

Supervisors and Regulators: Strengthening Oversight

AML compliance is enforced through active supervision.

Key Supervisory Authority

In the UAE, AML/CFT supervision is overseen by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD).

  • Established under the Central Bank of the UAE (CBUAE)

  • Responsible for supervising compliance across multiple sectors

  • Actively issues guidance, inspections, and enforcement actions

Since 2020, regulatory oversight has intensified, with consistent efforts to close gaps across all target sectors.

Special Focus on Emerging and Underdeveloped Markets

In sectors or regions where AML maturity is still developing, regulators apply heightened supervision.

Authorities pay closer attention to:

  • Newly established firms

  • Businesses with limited AML awareness

  • Sectors with historical enforcement weaknesses

Until these markets mature, strict monitoring remains essential to prevent abuse.

Practical AML Implementation Tips for Businesses

To strengthen AML compliance in 2025, businesses should:

  • Develop clear AML and KYC checklists

  • Use technology for screening and monitoring

  • Train employees regularly

  • Establish escalation procedures for high-risk cases

  • Conduct periodic AML audits

  • Engage professional AML advisors when needed

Consistent implementation is more important than complex documentation.

Why AML Compliance Is a Business Advantage

Strong AML frameworks do more than satisfy regulators. They:

  • Protect businesses from financial crime exposure

  • Enhance credibility with banks and partners

  • Reduce regulatory and reputational risk

  • Support long-term, sustainable growth

In today’s environment, AML compliance is not just a legal requirement—it is a core governance function.

AML compliance services in Dubai have become essential for businesses operating in high-value, cross-border, and regulated sectors. With increased enforcement in 2025, companies can no longer rely on minimal or outdated AML practices.

By adopting a risk-based approach, strengthening internal controls, and seeking expert guidance where needed, businesses can meet regulatory expectations while continuing to grow confidently.

Professional firms like Swenta assist organizations in navigating AML/CFT obligations with clarity, structure, and compliance certainty—without disrupting business operations.

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VAT on Mixed-Use Developments in the UAE: A Complete Guide for Businesses

Mixed-use developments are now a defining feature of the UAE’s real estate sector. Projects that combine residential units, retail outlets, offices, hotels, and shared facilities offer strong commercial value—but they also create complex VAT challenges.

As VAT enforcement tightens in 2025, businesses involved in mixed-use real estate must clearly understand how VAT applies, how input tax recovery works, and where compliance risks often arise. This guide explains VAT on mixed-use developments in simple, practical terms for developers, investors, and property managers operating in the UAE.

What Is a Mixed-Use Development Under UAE VAT?

A mixed-use development is a property project that includes both taxable and exempt supplies under UAE VAT law. Common examples include:

  • Residential apartments with retail shops below

  • Office towers connected to shopping malls

  • Hotels integrated into residential or commercial complexes

  • Projects with shared parking, amenities, and common areas

Because different parts of the same project are treated differently for VAT purposes, a single VAT approach cannot be applied across the entire development.

Why VAT Compliance Is More Complex for Mixed-Use Projects

VAT complexity arises because mixed-use developments typically involve:

  • Taxable supplies (commercial units, retail, hotels)

  • Exempt supplies (most residential leasing and sales)

  • Shared costs that support both taxable and exempt activities

This makes VAT apportionment, record-keeping, and documentation critical. Errors can result in denied VAT recovery, reassessments, and penalties during FTA audits.

Many developers engage VAT advisors such as Swenta at an early stage to ensure the project structure supports correct VAT treatment from the outset.

VAT Treatment by Property Type in Mixed-Use Developments

Understanding how VAT applies to each component is the foundation of compliance.

1. Residential Units

  • Lease or sale of residential property is generally VAT-exempt

  • First supply of new residential property within three years may be zero-rated

  • Input VAT related to exempt supplies is not recoverable

2. Commercial Units (Retail & Offices)

  • Subject to 5% VAT

  • VAT must be charged on rent or sale

  • Input VAT is generally recoverable

3. Hotels & Serviced Apartments

  • Treated as taxable accommodation

  • Subject to 5% VAT

  • Input VAT usually recoverable

4. Common Areas & Shared Facilities

  • Lobbies, lifts, parking, security, landscaping

  • VAT recovery depends on apportionment rules

Input VAT Recovery: The Biggest Risk Area

The most frequent VAT disputes in mixed-use developments relate to input VAT recovery.

Why Apportionment Is Required

Because costs often support both taxable and exempt supplies, VAT must be fairly allocated. Common shared costs include:

  • Construction and fit-out expenses

  • Consultant and professional fees

  • Maintenance and facilities management

  • Utilities and common services

Acceptable Apportionment Methods

  • Floor area method

  • Revenue-based method

  • Usage-based allocation

The method chosen must be reasonable, consistent, and well-documented. Poor apportionment is a key audit trigger in 2025.

VAT Considerations During the Development Phase

VAT obligations start long before the project is completed.

Key issues include:

  • VAT on contractor and supplier invoices

  • VAT on architects, engineers, and consultants

  • Classification of costs as recoverable or blocked

  • Cash-flow impact of unrecoverable VAT

Early VAT planning reduces the risk of costly corrections later.

VAT on Leasing vs Sale of Mixed-Use Property

Leasing

  • Residential lease → VAT-exempt

  • Commercial lease → 5% VAT

  • Clear separation in contracts and invoicing is essential

Sale

  • Residential sale → Exempt or zero-rated (subject to conditions)

  • Commercial sale → 5% VAT

Bundled pricing or unclear agreements often lead to VAT disputes.

Why Real Estate Is a High-Risk Sector for Regulators

Beyond VAT, real estate is closely monitored due to financial crime risks.

Why Real Estate Is Targeted

  • High transaction values enable large fund movements

  • Ownership can be concealed through third parties or shell entities

  • Funds become harder to trace once invested in property

  • Distorted property prices harm communities and economies

For these reasons, VAT compliance and AML expectations increasingly overlap in real estate transactions.

Risk-Based Approach (RBA) in Real Estate Compliance

A risk-based approach focuses enhanced controls on higher-risk transactions rather than applying the same checks everywhere.

In mixed-use developments, higher-risk areas include:

  • High-value property sales

  • Cross-border investors

  • Complex ownership structures

  • Unusual payment patterns

While VAT and AML are separate regimes, weak documentation in VAT often raises broader compliance concerns.

Key Compliance Steps for Real Estate Businesses

To manage VAT and regulatory risk effectively in 2025, businesses should:

1. Strengthen Documentation

  • Clear contracts separating residential and commercial use

  • Proper VAT invoices

  • Detailed apportionment calculations

2. Understand Each Transaction

  • Sale vs lease

  • Residential vs commercial use

  • Related-party transactions

3. Monitor Ongoing Relationships

  • Long-term tenants

  • Repeat investors or buyers

  • Changes in unit usage

4. Use Professional Support

VAT regulations evolve, and audits are increasingly technical. Professional advisors help businesses defend their VAT positions confidently.

Role of Supervisory Authorities in the UAE

Several authorities influence VAT and compliance in real estate:

  • Federal Tax Authority (FTA) – VAT audits and enforcement

  • AMLD – AML/CFT supervision since 2020

  • CBUAE – Oversight of financial integrity

Authorities increasingly expect aligned tax, governance, and compliance frameworks, especially in high-value sectors like real estate.

Special Focus on Emerging and Developing Markets

In newer or rapidly growing real estate areas:

  • Compliance systems may be immature

  • VAT awareness may be limited

  • Regulatory scrutiny is often higher

Until such markets mature, closer monitoring is the norm.

Practical Best Practices for VAT Compliance in 2025

To stay compliant and audit-ready:

  • Plan VAT structure at the design stage

  • Separate accounting for residential and commercial income

  • Use technology for VAT tracking and apportionment

  • Train finance and operations teams regularly

  • Review VAT positions annually

  • Seek expert VAT guidance for complex projects

Firms like Swenta assist businesses with VAT structuring, apportionment reviews, and FTA audit readiness—without over-complicating compliance.

VAT on mixed-use developments is one of the most technically demanding areas of UAE taxation. With tighter enforcement in 2025, businesses must move beyond basic compliance and adopt structured, well-documented VAT frameworks.

Getting VAT right protects cash flow, reduces audit risk, and supports long-term project profitability. In today’s regulatory environment, VAT compliance is not just a tax issue—it’s a core business responsibility.