As the UAE scales up its AML/CFT enforcement for 2025, one expectation stands out above all: every business must adopt a strong, well-documented, and genuinely effective Risk-Based Approach (RBA). This is no longer limited to banks—real estate firms, DNFBPs, consultants, corporate service providers, and SMEs all fall under increasing regulatory scrutiny.

Because of this, accounting firms now play a crucial role in helping UAE businesses design, implement, and maintain RBA-driven AML programs that meet the standards set by the Central Bank, the Ministry of Economy, and FATF.

In this guide, we explore how accounting firms support companies in building RBA systems, why it matters in 2025, and what gaps businesses must close immediately.

Why Real Estate Continues to Be a High-Risk Sector

Criminals consistently exploit the real estate sector, and the UAE is no exception. Several factors make this industry a prime target for money laundering:

1. High-Value Transactions Enable Fast Movement of Illicit Funds

A single purchase can disguise millions of dirhams, making it attractive for criminals seeking quick integration of illegal proceeds.

2. Historically Light Oversight Compared to Banking

Although regulations are now stricter, real estate still faces structural vulnerabilities that criminals attempt to exploit.

3. Complex Ownership Structures Hide True Beneficial Owners

Shell companies, offshore entities, and nominee buyers make it harder to determine who actually owns the funds.

4. Property Converts Illicit Money Into Hard Assets

Once a criminal invests in property, the asset becomes challenging to track, freeze, or confiscate.

This explains why authorities expect enhanced risk assessments, better customer profiling, and stronger monitoring from real estate players in 2025—and why accounting firms are indispensable in building compliant frameworks.

What Is a Risk-Based Approach (RBA)?

A Risk-Based Approach means prioritizing resources and controls based on the level of money laundering or terrorism financing risk associated with customers, sectors, regions, or transactions.

Rather than applying a one-size-fits-all rulebook, FATF requires businesses to:

• Identify and assess ML/TF risks

• Apply appropriate controls based on the level of risk

• Strengthen due diligence for higher-risk cases

• Conduct ongoing monitoring over time

• Update risk assessments as business models or customer behavior changes

Accounting firms such as Swenta help organisations tailor the RBA to their real operations—not generic templates, but sector-specific frameworks that withstand regulator inspections.

How Accounting Firms Help UAE Companies Implement an Effective RBA in 2025

Accounting and audit firms are uniquely positioned to support businesses because they understand financial flows, industry regulations, and internal control systems.

Below are the key ways they strengthen AML compliance:

1. Conducting Detailed AML Risk Assessments

An RBA begins with identifying exposure across several dimensions:

• Customer risk

• Geographic risk

• Product/service risk

• Transaction pattern risk

• Delivery channel risk

Accounting firms help businesses map and score these risks and prepare a formal AML Business Risk Assessment, which regulators now require during inspections.

2. Designing Customised AML Policies & Procedures

Many UAE companies still rely on copied or outdated AML manuals. Accounting firms redesign these to match:

• Company size

• Products and services

• Transaction volumes

• Customer profiles

• Sector-specific threats

A well-designed RBA policy becomes the foundation of every compliance action.

3. Implementing Proper KYC & Beneficial Ownership Procedures

Accounting firms guide businesses in establishing:

• Customer identification (KYC) requirements

• Verification methods

• Beneficial ownership (UBO) determination steps

• Risk-rating systems for onboarding

They also ensure documentation meets regulatory standards—one of the most common causes of fines in the UAE.

4. Strengthening Transaction Monitoring Systems

A true RBA requires continuous monitoring, not one-time checks.

Accounting firms help companies:

• Identify abnormal transaction patterns

• Flag unusual payment methods

• Detect structuring, layering, or unexplained transfers

• Apply enhanced monitoring for higher-risk clients

This is crucial for DNFBPs, which often lack automated monitoring tools.

5. Supporting STR/SAR Reporting Requirements

Many companies fail to recognize when a suspicious transaction should be reported. Accounting firms provide:

• Red flag training

• Guidance on identifying suspicious indicators

• Assistance in preparing STRs through goAML

• Support during regulator inquiries

Submitting STRs correctly and promptly is one of the UAE’s top AML expectations for 2025.

6. Providing Staff Training Aligned With RBA Requirements

Regulators require all employees—not just compliance officers—to understand:

• ML/TF risks

• Red flags

• Customer risk categorisation

• EDD vs. CDD differences

• Internal reporting procedures

Accounting firms conduct industry-specific training that meets AMLD’s competency expectations.

7. Helping With Ongoing Reviews & AML Audits

A Risk-Based Approach is not static. It must evolve as business risks change.

Accounting firms support businesses with:

• Annual AML effectiveness reviews

• Internal audits

• Gap assessments

• Updates to RBA methodologies

• System improvements after regulatory changes

This ensures companies remain compliant year after year—not just at onboarding.

Why Supervisors Expect More from Companies in 2025

The AMLD and Ministry of Economy are intensifying oversight across all sectors. Their goals include:

• Better sector-wide risk understanding

• Higher quality STRs

• Stronger beneficial ownership compliance

• More accurate record-keeping

• Industry-level capability building

Where sectors are still developing—such as property brokers, consultants, or e-commerce—regulators are applying stricter monitoring to reduce exposure.

Practical Steps UAE Companies Should Take Now

To build or strengthen an RBA framework, businesses should:

• Create structured due diligence checklists

• Adopt technology to identify riskier customers

• Use screening tools for PEPs and sanctions lists

• Train teams regularly

• Apply EDD for high-risk clients

• Conduct annual AML gap assessments

• Seek expert guidance from AML advisors in the UAE

Even small improvements can significantly reduce non-compliance risk in 2025.

The Risk-Based Approach is no longer a recommendation—it is a mandatory regulatory standard. With penalties rising and enforcement tightening, UAE companies must build solid AML frameworks backed by evidence, documentation, and continuous monitoring.

Accounting firms such as Swenta help organisations:

• Understand their risks

• Implement practical controls

• Improve compliance efficiency

• Ensure readiness for regulator inspections

With the right support, businesses can meet 2025’s stringent AML expectations confidently and avoid serious penalties.