As global regulatory bodies intensify their focus on financial crime, the Financial Action Task Force (FATF) has introduced new monitoring expectations for 2025 that significantly affect how UAE businesses must operate. The UAE has progressed strongly in recent years, and 2025 marks a period of deeper alignment with global standards—especially for AML, KYC, and risk-based supervision.

For companies across the country, this means stricter documentation requirements, enhanced reporting accuracy, robust customer due diligence, and a higher level of readiness for regulatory reviews. Accounting and audit firms, including Swenta, now play a more strategic role than ever in helping organizations meet these expectations.

Why the FATF Is Increasing Monitoring in the UAE

The FATF’s new oversight framework for 2025 focuses on strengthening transparency, combating complex money-laundering networks, and closing gaps in high-risk sectors. Several industry segments—including real estate, jewellery, legal practices, corporate service providers, and accounting firms—face increased scrutiny due to their exposure to illicit finance.

But one sector stands out more than others.

Why Real Estate Continues to Be Targeted

Criminals still gravitate toward real estate when attempting to launder funds. The reasons are persistent and clear:

1. High-Value Transactions Enable Quick Movement of Large Sums

A single purchase can conceal millions—making real estate an attractive laundering channel.

2. Historically Lower Regulation Compared to Banking

Real estate involves fewer institutional checks, creating opportunities for criminals to mask ownership or funding origin.

3. Complex Ownership Structures Hide Beneficial Owners

Shell entities, layered companies, nominees, and third-party buyers can obscure true ownership.

4. Purchased Property Makes Funds Hard to Trace

Once illicit money is converted into assets, recovering it becomes challenging for authorities.

The consequences go beyond financial crime: rising property values, community distortion, and greater economic inequality.

Understanding FATF’s Reinforced Risk-Based Approach (RBA) in 2025

The Risk-Based Approach sits at the heart of FATF’s monitoring expectations for 2025. Instead of performing the same level of checks for every client, businesses must:

• Identify high-risk transactions or customers

• Apply enhanced due diligence (EDD) where needed

• Continuously assess risks across all business activities

• Update internal controls based on evolving threats

• Maintain detailed documentation of assessments

For many companies, applying the RBA effectively requires expert support from AML specialists and accounting firms who understand local and global regulatory demands.

Key Steps FATF Expects Real Estate Professionals to Follow

FATF’s heightened expectations mean UAE real estate firms must strengthen compliance in several areas:

1. Conduct Stronger KYC Verification

This includes validating:

• Identity documents

• Beneficial ownership

• The actual source of funds

• Whether a customer is acting on behalf of another person

2. Analyse the Commercial Logic of Transactions

Businesses must question:

• Is the deal overly complicated?

• Is the value inconsistent with market rates?

• Does the transaction pattern appear unusual?

These are red flags requiring further investigation.

3. Trace the Movement of Funds

Cash transactions, offshore transfers, and opaque payment structures demand enhanced scrutiny.

4. Monitor Ongoing Relationships

Regular clients can change their behaviour over time, and businesses must:

• Refresh documentation

• Perform periodic due diligence

• Identify abnormal patterns

• Flag and report suspicious activity

5. Engage AML Consultants or Accounting Firms

Professional AML advisors in the UAE help businesses:

• Implement FATF-aligned procedures

• Prepare for AMLD regulatory audits

• Build risk assessment frameworks

• Submit accurate goAML reports

This dramatically reduces compliance risks.

Regulators Have Also Increased Their Responsibilities

Real estate agents, jewellers, lawyers, and accountants carry significant AML duties, but regulators have also intensified their approach.

The UAE’s AMLD (Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department) has:

• Expanded the scope of inspections

• Introduced stricter sectoral guidelines

• Required more training for compliance officers

• Implemented deeper monitoring across DNFBPs

• Tightened controls in developing or high-risk markets

Supervisors are now expected to build the capacity of the sectors they regulate—ensuring all businesses are fully capable of meeting AML/CFT standards.

Special Attention for Emerging or Underdeveloped Markets

FATF’s 2025 monitoring priorities include regions or business sectors where compliance infrastructure is still weak. Authorities are instructed to monitor closely:

• Newly licensed real estate agencies

• Small or untrained jewellery shops

• New legal or consulting practices

• Businesses with low AML awareness

• Regions where enforcement has historically been weak

Without strong internal controls, these sectors can become entry points for illicit financial flows.

Practical Steps Businesses Must Take to Prepare for FATF 2025 Expectations

To align with the new global standards, UAE companies should implement the following:

✔ Create detailed KYC and due diligence checklists

Clear procedures ensure staff follow consistent steps.

✔ Use automation to detect red flags

Technology solutions help identify unusual transaction patterns early.

✔ Train employees regularly

Ongoing sessions keep staff updated on AML threats and FATF trends.

✔ Establish internal rules for high-risk cases

Enhanced checks must be performed for clients or deals that trigger risk indicators.

✔ Maintain thorough records

Document everything—risk assessments, communications, approvals, and due diligence actions.

✔ Seek support from AML advisors or accounting experts

Firms like Swenta help businesses bridge compliance gaps and meet FATF expectations confidently.

The UAE is committed to strengthening its global reputation and financial integrity. With FATF expanding its monitoring framework in 2025, companies must adopt stronger, smarter, and more transparent AML controls.

Accounting and AML specialists such as Swenta provide the expertise, structure, and regulatory guidance businesses need to keep pace with rising global expectations and avoid penalties.

Preparing early means protecting your business from unnecessary risks—and building a compliance foundation that supports sustainable growth.