In 2025, AML enforcement in the UAE is increasingly shaped by one reality: accountants often see suspicious activity long before banks flag it.

While banks rely on transaction monitoring systems and predefined thresholds, accountants sit closer to the commercial substance of transactions. They see contracts, ledgers, adjustments, and explanations—or the lack of them. This proximity allows accountants to identify inconsistencies that automated banking systems may miss entirely.

This article explains how accountants detect suspicious activity before banks, why real estate remains a prime risk area, how the risk-based approach (RBA) applies in practice, and what UAE regulators expect from businesses today.

Why Accountants Have an AML Advantage

Banks see money flows.
Accountants see why those money flows exist.

This difference is critical.

Accountants review:

• Contracts and agreements

• Invoices and supporting documents

• Ledger classifications and adjustments

• Timing differences and reconciliations

• Business rationale behind transactions

Because of this, accountants often detect economic inconsistencies long before a transaction triggers a bank’s automated alert.

Why Real Estate Is a Key Focus Area

Real estate continues to attract heightened AML scrutiny in the UAE.

Criminals prefer real estate because:

• Properties are high in value, allowing large sums to move at once

• Ownership structures can be layered through entities or nominees

• The sector has historically been less regulated than banks

• Once funds convert into property, they become harder to trace or seize

In several jurisdictions, illicit real estate transactions have distorted markets and priced out legitimate buyers. These consequences explain why UAE regulators expect earlier detection of risks, especially from professionals closest to the transaction—accountants.

How Accountants Spot Suspicious Activity Early

1. Transactions That Lack Commercial Logic

Accountants often notice when:

• Prices are far above or below market value

• Payment terms do not match the deal structure

• Transactions are unnecessarily complex

Banks may process the payment, but accountants ask: “Why does this deal exist in this form?”

2. Mismatch Between Records and Reality

Suspicious activity often appears as:

• Revenue without corresponding operational activity

• Advances received with no clear purpose

• Assets recorded without physical or legal support

These inconsistencies raise red flags before any external reporting occurs.

3. Repeated Adjustments and Manual Journals

Frequent manual entries, reversals, or reclassifications can signal:

• Attempts to normalize unusual flows

• Structuring or layering behavior

• Poorly documented transactions

Accountants see these patterns over time—banks usually do not.

4. Source-of-Funds Gaps

When accountants cannot trace:

• Where funds originated

• Why a third party is paying

• Why offshore accounts are involved

they identify AML risk immediately—even if the bank has not yet flagged the transaction.

5. Client Behavior That Changes Quietly

Accountants often notice:

• Sudden spikes in transaction volume

• New payment patterns

• Shifts in deal structures

Because they review historical data holistically, these changes stand out faster than they do in bank monitoring systems.

The Risk-Based Approach in Action

Under guidance from the Financial Action Task Force (FATF), businesses must apply a risk-based approach (RBA)—focusing enhanced controls where risk is higher.

Accountants play a central role in RBA because:

• Risk cannot be assessed without understanding financial substance

• High-risk transactions require deeper financial analysis

• Low-risk activity should still remain explainable and consistent

When accountants apply RBA thinking during reviews, suspicious activity is identified before it reaches the banking system.

Why Banks Often Detect Risk Later

Banks typically:

• Rely on automated thresholds

• Focus on transaction size and frequency

• Lack visibility into underlying contracts

This means:

• Structuring below thresholds may go unnoticed

• Complex but “clean-looking” transactions may pass

• Contextual risks are often invisible

Accountants fill this gap by linking numbers to real-world business logic.

Regulatory Expectations in the UAE

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

Recent inspections show regulators increasingly:

• Review accounting records alongside AML files

• Interview finance and accounting teams

• Trace suspicious activity from ledgers, not just banks

• Penalize failures to escalate early warning signs

In several cases, regulators concluded that accountants had enough information to detect risk earlier—but escalation failed.

Emerging and Weakly Regulated Markets

In fast-growing or underdeveloped markets, accountants’ role becomes even more critical.

Regulators pay close attention to:

• New real estate businesses

• Rapid growth without system maturity

• Family-owned or relationship-driven structures

Without accountant-led scrutiny, these environments can become unintentional entry points for illicit funds.

Practical Steps for Accountants to Strengthen AML Detection

To identify suspicious activity early, accountants should:

• Question transactions that lack commercial sense

• Document explanations for unusual entries

• Align accounting reviews with AML risk ratings

• Escalate repeated anomalies promptly

• Coordinate closely with compliance teams

• Receive regular AML-focused training

Many businesses engage experienced advisors to help accounting teams integrate AML thinking into daily reviews.

Why Early Detection Protects the Business

When accountants identify suspicious activity early:

• Issues are addressed before regulatory exposure grows

• Banks are less likely to freeze accounts unexpectedly

• Inspections proceed more smoothly

• Penalty risk is significantly reduced

In 2025, regulators increasingly view accountant-led detection as a sign of AML maturity.

Banks play a vital role in AML reporting—but accountants are often the first to see something is wrong. By understanding business substance, transaction logic, and financial patterns, accountants detect suspicious activity long before it triggers automated alerts.

For real estate and other high-risk sectors in the UAE, this early warning role is no longer optional—it is an expectation. Businesses that empower accountants to think beyond bookkeeping and act as risk identifiers will be far better positioned to meet regulatory expectations and operate with confidence.