As AML enforcement in the UAE becomes more outcomes-focused, periodic AML reviews have moved from a “best practice” to a regulatory expectation. In 2025, regulators are no longer asking whether businesses conduct risk assessments—they are asking how often risks are reassessed, how changes are identified, and how quickly controls are updated.

For UAE businesses operating under AML/CFT obligations, especially in higher-risk sectors such as real estate, corporate services, and professional services, periodic AML reviews are critical to staying inspection-ready and avoiding penalties.

This guide explains how often AML risks should be reassessed in 2025, what regulators expect to see during inspections, and how businesses can build a sustainable review cycle aligned with a risk-based approach.

Why Periodic AML Reviews Matter More in 2025

Money laundering risks do not remain static. Customer profiles change, transaction behaviors evolve, regulations tighten, and new typologies emerge. A risk assessment performed once and never updated quickly becomes outdated.

UAE regulators increasingly flag the following during AML examinations:

• Risk assessments not updated for years

• Customer risk ratings that never change

• Controls that do not reflect current business activities

• AML policies copied from templates without periodic review

In 2025, failure to reassess risk regularly is viewed as a weakness in governance, not a procedural oversight.

Why Real Estate Remains a Priority Sector for AML Reviews

Real estate continues to receive heightened regulatory attention, making periodic AML reviews especially important in this sector.

Criminals prefer real estate because:

• High-value transactions allow movement of large sums in a single deal

• Lower historical regulation compared to banks creates vulnerabilities

• Use of shell companies or nominees can conceal true ownership

• Asset conversion makes illicit funds harder to trace or seize

Once illicit money is invested in property, recovering or freezing it becomes significantly more complex. In several countries, unchecked laundering through real estate has distorted property markets and harmed communities.

As a result, regulators expect more frequent and deeper AML reviews from real estate professionals than from lower-risk sectors.

Understanding the Risk-Based Approach (RBA)

A risk-based approach (RBA) means focusing compliance resources where they are needed most. Rather than applying identical controls to all customers and transactions, businesses assess:

• Which customers pose higher risk

• Which products or services are more vulnerable

• Which geographies or transaction types increase exposure

According to FATF guidance, every country should require real estate agents, brokers, and related professionals to assess and periodically reassess money laundering and terrorist financing risks.

Periodic AML reviews are the mechanism that keeps the RBA alive and effective, rather than theoretical.

How Often Should AML Risks Be Reassessed in 2025?

There is no single timeline that fits all businesses. In 2025, regulators expect frequency to align with risk exposure.

1. Enterprise-Wide Risk Assessment (EWRA)

• Low to medium-risk businesses: At least once every 12–24 months

• High-risk sectors (e.g., real estate, DNFBPs): Annually, or sooner if major changes occur

An EWRA should also be updated immediately after:

• Launching new products or services

• Entering new markets or jurisdictions

• Significant regulatory changes

• Major enforcement actions in the sector

2. Customer Risk Reviews

Customer risk should not be assessed only at onboarding.

Best practice in 2025:

• Low-risk customers: Review every 2–3 years

• Medium-risk customers: Review every 12–24 months

• High-risk customers / PEPs: Review at least annually, or more frequently

Trigger events such as unusual transactions, ownership changes, or negative media should prompt immediate reassessment.

3. Transaction Monitoring Effectiveness Reviews

Regulators now expect businesses to periodically review whether their monitoring systems still make sense.

This includes:

• Reviewing alert thresholds

• Testing scenarios against recent typologies

• Assessing false positives vs. missed risks

Many firms now perform annual transaction monitoring effectiveness reviews as part of their AML program.

Key Steps for Real Estate Professionals During Periodic AML Reviews

To align with regulatory expectations, real estate professionals should focus on the following during AML reviews.

1. Review KYC and Beneficial Ownership Files

AML reviews should verify whether:

• Customer identification documents are still valid

• Beneficial ownership information is complete and current

• Changes in ownership structures have been captured

Outdated KYC files are one of the most common regulatory findings.

2. Reassess the Purpose and Nature of Transactions

Businesses should revisit:

• Whether transactions still align with customer profiles

• Whether deal structures remain commercially logical

• Whether pricing is consistent with market conditions

Unexplained complexity or irrational pricing should elevate risk.

3. Reevaluate Source of Funds and Wealth

AML reviews must confirm that:

• Source-of-funds explanations remain credible

• Funding patterns have not changed unexpectedly

• Offshore transfers or cash usage are justified

Changes in funding behavior are a key trigger for enhanced due diligence.

4. Monitor Ongoing Relationships Actively

For repeat clients, periodic AML reviews should assess:

• Frequency and value of transactions over time

• Shifts in behavior compared to historical patterns

• Increased use of third parties or intermediaries

Static monitoring is a clear red flag for regulators.

The Role of AML Consultants in Periodic Reviews

Many UAE businesses struggle to balance compliance depth with operational efficiency. AML consultants in the UAE often support periodic reviews by:

• Conducting independent AML health checks

• Updating risk assessments and scoring models

• Identifying gaps regulators are likely to flag

• Preparing businesses for AML inspections

Accounting and advisory firms like Swenta often assist clients in embedding structured review cycles that are both practical and inspection-ready—without overburdening operations.

Supervisors and Regulators: What They Expect in 2025

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

During inspections, regulators typically assess:

• Whether AML reviews are documented and periodic

• How risks are identified, updated, and escalated

• Whether findings result in real control improvements

• Board and senior management oversight of review outcomes

Where sectors are still developing, regulators apply closer scrutiny until risk management maturity improves.

Special Focus on Weak or Emerging Markets

In markets where AML awareness is still evolving, regulators pay special attention to:

• Newly established businesses

• Firms entering high-risk sectors

• Regions with historically weak enforcement

Frequent and well-documented AML reviews help prevent these markets from becoming safe havens for illicit funds.

Practical Best Practices for 2025

To strengthen periodic AML reviews, UAE businesses should:

• Maintain a documented AML review calendar

• Define clear triggers for off-cycle reviews

• Assign ownership for review outcomes

• Use technology to track risk changes

• Train staff to recognize evolving risk indicators

AML reviews should be continuous, structured, and actionable—not a box-ticking exercise.

In 2025, periodic AML reviews are no longer optional or administrative. They are a core pillar of effective risk management and regulatory compliance in the UAE.

Businesses that reassess risk regularly, respond quickly to changes, and document their decisions clearly are far better positioned to pass inspections and protect their reputation. With a strong risk-based framework and expert guidance where needed, periodic AML reviews become a strategic advantage rather than a regulatory burden.