As the UAE strengthens its AML/CFT framework in alignment with FATF recommendations, KYC refresh cycles have become one of the most important compliance obligations for businesses in 2025. Whether you operate in real estate, jewellery, legal services, corporate structuring, or accounting, keeping customer records updated is no longer optional—it is mandatory.

Many businesses mistakenly believe that KYC is a one-time activity conducted during onboarding. In reality, the UAE now requires continuous and periodic updating of customer information based on risk level, business relationship, and transaction behaviour.

This guide explains what has changed in 2025, why KYC refresh matters, and how accounting firms like Swenta help companies stay compliant without operational disruption.

Why Real Estate Is Frequently Targeted for Money Laundering

Real estate has historically attracted illicit funds, especially through cross-border channels. Criminals rely on it because:

1. The transactions are high in value

A single purchase allows the movement of millions with minimal visibility.

2. Historically lighter regulation than banking sectors

This made it easier to hide the origin of funds.

3. Ownership can be masked

Shell companies, proxies, and layered legal structures can conceal the true beneficial owner.

4. Property “locks” illegal money

Once invested in real estate, funds become harder to seize or trace.

Globally, this trend has distorted property markets and harmed communities. The UAE’s updated AML regulations aim to prevent the sector from being misused in similar ways.

What Is a Risk-Based Approach (RBA) and Why It Matters for KYC Refresh?

The UAE’s compliance framework relies heavily on the Risk-Based Approach (RBA).
This means businesses must spend more time and resources on customers who pose higher risks. Instead of treating all clients alike, companies must:

• Identify the risk category of each client

• Set refresh intervals based on risk levels

• Apply enhanced due diligence (EDD) where needed

• Monitor the client relationship continuously

According to FATF guidelines, every regulated business must assess the likelihood of ML/TF risks and adjust its KYC policies accordingly.

AML consultants in Dubai—and compliance specialists at Swenta—help companies build and maintain these RBA-driven KYC programs.

KYC Refresh Cycles in UAE 2025: What Has Changed?

For 2025, UAE authorities have expanded and clarified refresh requirements for all Designated Non-Financial Businesses and Professions (DNFBPs), including:

• Real estate brokers

• Jewellery and precious metal dealers

• Lawyers and legal consultants

• Corporate service providers

• Accountants and auditors

Updated KYC Refresh Intervals Based on Risk Levels

High-risk clients may include:

• Politically exposed persons (PEPs)

• Clients from high-risk jurisdictions

• Clients involved in complex ownership structures

• Those using offshore entities

• Businesses with unexplained transaction patterns

The refresh cycle ensures customer profiles remain accurate and updated—preventing criminals from exploiting outdated information.

Key Steps for KYC Refresh in UAE

To meet updated regulatory requirements, businesses must perform the following steps:

1. Re-verify Customer Identity

Obtain updated documents such as:

• Passports

• Emirates IDs

• Trade licenses

• Proof of address

• Beneficial owner declarations

This ensures the client’s profile remains accurate.

2. Reassess the Nature and Purpose of the Business Relationship

Ask:

• Has the client’s business activity changed?

• Are they expanding into new sectors or geographies?

• Is the complexity of their structure increasing?

Any unusual changes should trigger enhanced due diligence.

3. Review Source of Funds (SOF) and Source of Wealth (SOW)

Funds coming from:

• Offshore accounts

• Cryptocurrencies

• High-risk jurisdictions

• Sudden large inflows

…should be examined closely.

4. Conduct Ongoing Transaction Monitoring

Businesses must track:

• Sudden spikes in activity

• Transactions inconsistent with client profile

• Deals involving unusual jurisdictions

• Use of cash-heavy patterns or layered transfers

Monitoring is continuous—not just periodic.

5. Update Risk Scoring

Clients may move from low to high risk or vice versa.
Risk scores must be updated accordingly, and refresh cycles adjusted.

Why Supervisors Are Increasing Pressure in 2025

The UAE AMLD (Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department) has significantly intensified compliance inspections. The focus is especially strong in:

• Real estate

• Jewellery and gold trading

• Legal and corporate consultancy

• Accounting and auditing firms

These sectors are at higher risk due to their exposure to complex financial flows, cross-border clients, and layered ownership networks.

Authorities are also targeting:

• New or inexperienced firms

• Companies with limited AML awareness

• Businesses in regions with weak enforcement history

This ensures no gaps remain for criminals to exploit.

Practical Steps Businesses Should Implement Immediately

Here are actionable compliance measures for 2025:

• Create structured KYC refresh checklists

• Use automated systems for reminders and alerts

• Train staff on identifying outdated or suspicious records

• Document every refresh action for audit evidence

• Apply enhanced due diligence for high-risk clients

• Partner with AML advisors in UAE for professional oversight

How Swenta Helps Businesses Meet KYC Refresh Requirements

Swenta supports companies by:

• Designing KYC refresh frameworks

• Conducting risk assessments and client reclassification

• Implementing automated KYC monitoring systems

• Handling document verification and record updating

• Training internal teams on new 2025 requirements

• Preparing businesses for AMLD inspections

• Conducting AML audits to ensure compliance gaps are eliminated

With expert guidance, businesses avoid penalties and maintain fully compliant operations.

With strengthened regulations and enhanced supervision, UAE businesses must ensure that KYC information stays accurate, updated, and risk-aligned. The era of “onboarding-only KYC” is over—2025 demands continuous monitoring, structured refresh intervals, and proactive compliance.

Businesses that invest in strong systems today will avoid disruptions, penalties, and reputational damage tomorrow. With support from accounting and compliance specialists like Swenta, companies can operate confidently in a heavily regulated environment.