In 2025, the UAE’s regulatory landscape continues to shift rapidly as authorities tighten expectations around Anti-Money Laundering (AML) and Corporate Governance. What was once seen as two separate compliance areas—financial crime prevention and organisational oversight—has now become deeply interconnected. Today, strong AML practices cannot exist without solid governance, and governance frameworks are incomplete without effective AML controls.

For UAE companies, this convergence is not optional. It is a regulatory obligation, a strategic necessity, and a risk mitigation tool essential for long-term stability. As the UAE strengthens its AML/CFT system in alignment with FATF standards, the pressure on boards, senior management, compliance teams, and financial officers has never been greater.

Why Financial Crime Risk Expands Governance Responsibilities

Money laundering affects far more than balance sheets. It destabilises industries, distorts markets, and damages national reputation. One sector where these impacts are visible globally is real estate.

Why Real Estate Is a Major AML Hotspot

Criminals favour real estate for several reasons:

1. High-Value Assets Allow Rapid Movement of Illicit Funds

A single property transaction can disguise huge sums, making it attractive for criminals seeking fast integration of illegal proceeds.

2. Historically Lower Oversight Compared to Banks

While regulations have tightened, gaps still exist—especially in documentation, beneficial ownership transparency, and source-of-funds checks.

3. Complex Ownership Structures Mask Beneficial Owners

Layering through offshore entities or nominee buyers helps criminals hide the real source of funds.

4. Hard-to-Trace Asset Conversion

Once money is invested in property, retrieving it becomes difficult. This pushes prices up in some markets, distorting affordability and harming communities.

These impacts go beyond finance—they affect governance, reputation, and the integrity of entire industries.

How Corporate Governance and AML Converge in 2025

Corporate governance in the UAE is increasingly expected to support AML compliance, not operate separately from it. Authorities now evaluate whether companies demonstrate:

• Clear accountability from the board and senior management

• Risk awareness and documented decision-making

• Internal controls aligned with ML/TF risks

• Proper oversight of onboarding, payments, and customers

• Transparent ownership structures and accurate UBO data

Governance frameworks are evolving to ensure businesses are not only profitable but also ethical, transparent, and resilient against financial crime.

Why a Risk-Based Approach (RBA) Is Now a Governance Requirement

An AML Risk-Based Approach (RBA) directs attention and resources to higher-risk areas rather than applying the same controls to all customers or transactions.

According to FATF, all businesses—especially those in real estate, corporate services, consulting, and financial sectors—must:

• Identify risks relevant to their activities

• Document ML/TF exposures

• Apply enhanced checks to higher-risk customers

• Maintain ongoing monitoring as risks evolve

In 2025, regulators increasingly hold management accountable if the RBA is missing, outdated, or ineffective.

Accounting firms and AML consultants, such as Swenta, play a key role in helping UAE companies design governance structures that reflect and support a strong RBA.

Key Governance Duties That Directly Support AML in UAE Companies

1. Leadership Ownership of AML Policies

Boards must approve AML frameworks, understand risk exposure, and ensure resources are available for compliance.

2. Independent Oversight and Internal Controls

Internal audits, AML reviews, and risk committees ensure transparency and detect weak spots early.

3. Documented Beneficial Ownership Transparency

Companies must maintain accurate, updated UBO records. Hidden ownership is a major red flag—and a major governance failure.

4. Ethical Culture and Employee Accountability

Governance increasingly includes building a culture where employees recognise and report suspicious activity.

5. Accurate Record-Keeping and Decision Logs

Regulators look for documentation proving that governance was exercised—not merely stated.

Regulators Are Increasing Expectations Across All Sectors

The UAE’s AMLD (Anti-Money Laundering and CFT Supervision Department), formed under the Central Bank in 2020, continues tightening its oversight. Authorities expect:

• More robust internal AML controls

• Better quality KYC and EDD processes

• Improved reporting of suspicious transactions

• Higher awareness across non-financial sectors

• Stronger documentation during inspections

Sectors still maturing—such as real estate, e-commerce, consultants, and corporate service providers—are under closer scrutiny because of higher vulnerability.

A Special Focus on Emerging or Weakly Regulated Markets

Supervisors pay special attention to areas with:

• New market entrants

• Limited AML awareness

• Weak historical enforcement

• Reliance on third-party agents

• High cash intensity or international flows

These risks make governance frameworks even more vital.

Practical Governance and AML Steps UAE Companies Should Implement in 2025

Companies can strengthen both governance and AML by:

• Creating structured AML checklists and workflows

• Integrating automated tools to flag unusual transactions

• Training employees regularly, not once a year

• Setting internal thresholds for higher-risk scenarios

• Monitoring customers continuously

• Conducting periodic AML governance assessments

• Seeking advice from AML consultants and accounting professionals

A strong governance framework is no longer just about compliance—it’s about resilience.

In 2025, AML compliance is becoming a central pillar of corporate governance in the UAE. Boards and finance teams are now expected to demonstrate active oversight, risk management, and transparency. Companies that fail to integrate AML into governance expose themselves to:

• Financial penalties

• Regulatory investigations

• Reputational damage

• Loss of business licenses

With proper guidance—from advisors such as Swenta—organisations can build governance structures that not only meet regulatory expectations but also enhance long-term trust and business stability.