As AML enforcement in the UAE intensifies, 2025 is shaping up to be a critical year for regulatory inspections and examinations. Authorities are no longer satisfied with surface-level compliance or “tick-box” documentation. Instead, they are evaluating whether businesses truly understand, manage, and mitigate money laundering and terrorist financing risks.

Accounting and audit firms across the UAE are seeing a clear trend: many businesses fail AML examinations not because they lack policies, but because those policies are ineffective in practice. This article explains what regulators are focusing on in 2025 and what experienced accounting firms advise companies to fix first to stay inspection-ready.

Why AML Examinations Are Becoming Stricter in the UAE

The UAE has made significant progress in strengthening its AML/CFT framework in recent years. Regulatory bodies are now placing greater emphasis on how AML programs operate in real business environments, especially in higher-risk sectors such as real estate, trading, professional services, and DNFBPs.

Regulators are paying closer attention to:

• Quality of risk assessments

• Depth of customer due diligence

• Consistency between policy and practice

• Board and senior management involvement

• Effectiveness of transaction monitoring and reporting

In short, having documents is no longer enough. Businesses must demonstrate that AML controls are embedded into daily operations.

Why Real Estate Remains a High-Risk Focus Area

Real estate continues to attract regulatory scrutiny globally, including in the UAE. Criminals prefer property transactions for several reasons.

First, real estate involves high-value assets, allowing large sums of money to move in a single transaction. Second, compared to banks, the sector has historically faced lighter operational controls, making it easier to hide beneficial ownership behind nominees, shell companies, or third parties. Third, once funds are invested in property, they become harder to trace and recover.

In many jurisdictions, unchecked financial crime in real estate has distorted markets and harmed local communities. As a result, UAE authorities now expect real estate professionals and related businesses to apply robust AML controls comparable to those in financial institutions.

The Risk-Based Approach: A Core Examination Pillar in 2025

A risk-based approach (RBA) sits at the center of AML examinations in 2025. Regulators want proof that businesses understand where their real risks lie and allocate resources accordingly.

Rather than applying the same checks to every customer or transaction, an RBA requires companies to:

• Identify higher-risk customers, products, and jurisdictions

• Apply enhanced due diligence where risk is elevated

• Maintain proportionate controls for lower-risk activities

FATF standards require countries, supervisors, and regulated entities to adopt this approach. In the UAE, inspectors frequently test whether risk assessments are realistic, current, and actually used to guide decisions.

Accounting and AML advisory firms in Dubai regularly assist clients in redesigning risk frameworks that are practical, defensible, and aligned with regulatory expectations.

What Accounting Firms Advise Clients to Fix First

Based on recent examinations and regulatory feedback, accounting firms consistently identify the same problem areas during AML readiness reviews.

1. Weak or Outdated Risk Assessments

Many businesses rely on generic templates that do not reflect their actual operations. Regulators now expect risk assessments to:

• Be business-specific

• Consider customer profiles, transaction types, delivery channels, and geographies

• Be reviewed and updated regularly

If your risk assessment has not changed in years, it is likely to fail an inspection.

2. Incomplete or Inconsistent KYC Files

Know Your Customer (KYC) remains a foundational AML requirement. During examinations, inspectors often find:

• Missing identification documents

• No verification of beneficial ownership

• Lack of ongoing customer review

Businesses must verify not just who the customer is, but who ultimately owns or controls the funds, even when intermediaries are involved.

3. Poor Understanding of Transactions and Business Purpose

Regulators increasingly test whether companies understand why a customer is entering into a transaction. Red flags include:

• Unusual deal structures

• Prices that do not align with market norms

• Complex arrangements with no clear commercial logic

Failure to question these indicators signals weak internal controls.

4. Inadequate Source of Funds Checks

One of the most common AML examination failures involves insufficient source-of-funds analysis. Inspectors expect businesses to:

• Identify how customers generated their funds

• Scrutinize cash-heavy or offshore transactions

• Escalate higher-risk cases for enhanced review

Merely recording payment details is no longer sufficient.

5. Lack of Ongoing Monitoring

AML is not a one-time exercise. Regulators expect continuous monitoring of business relationships. This includes:

• Reviewing changes in customer behavior

• Identifying unusual transaction patterns

• Updating risk profiles when circumstances change

Static compliance programs are a major red flag in 2025.

The Role of Supervisors and Regulators

Businesses are not expected to manage AML risk alone. In the UAE, supervision is led by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD), established under the Central Bank of the UAE.

Since 2020, AMLD has steadily increased oversight across sectors. Authorities are particularly focused on industries that are:

• Rapidly expanding

• New to AML obligations

• Historically under-regulated

Where market maturity is still developing, inspections tend to be more frequent and detailed.

Special Attention to Emerging and Higher-Risk Markets

Regulators pay closer attention to:

• Newly licensed firms

• Businesses operating in high-risk jurisdictions

• Sectors with limited AML awareness

These environments are more vulnerable to misuse, making strong supervision essential. Businesses operating in such areas must demonstrate heightened awareness and stronger controls.

Practical Steps to Improve AML Examination Readiness

Accounting firms typically recommend the following actions before an inspection:

• Conduct an independent AML gap assessment

• Update and document risk-based policies

• Create standardized due diligence checklists

• Implement technology for transaction monitoring

• Train staff regularly with role-specific AML programs

• Establish clear escalation and reporting procedures

Seeking guidance from experienced AML advisors in the UAE can significantly reduce regulatory risk and inspection stress.

How Accounting Firms Add Value to AML Readiness

Accounting and audit firms play a critical role in bridging the gap between regulation and practice. Firms like Swenta, working across audit, tax, and compliance advisory, help businesses translate legal requirements into operational systems that regulators expect to see.

The goal is not just to pass an inspection, but to build a sustainable AML framework that protects the business long-term.

AML examinations in the UAE are becoming deeper, more targeted, and more outcome-driven. In 2025, businesses that wait until an inspection notice arrives are already too late.

By addressing common weaknesses early and adopting a genuine risk-based approach, companies can move from reactive compliance to confident regulatory readiness.