The UAE’s regulatory landscape continues to transform rapidly, and by 2025, AML compliance has become one of the most critical obligations for Designated Non-Financial Businesses and Professions (DNFBPs). Industries such as real estate, jewellery trading, and legal services face heightened scrutiny due to their exposure to financial crime risks and their involvement in high-value or complex transactions.

With strict penalties and enhanced inspections now in place, businesses across these sectors increasingly rely on audit and accounting firms like Swenta to help them build, maintain, and monitor AML frameworks that align with the UAE’s evolving regulations.

This guide breaks down the updated AML requirements for DNFBPs, the risks they face, and how professional accountants offer essential compliance support.

Why Real Estate Is Highly Targeted Under AML Regulations

Criminals continue to exploit the real estate sector globally, and the UAE is no exception. The following characteristics make real estate an attractive avenue for money laundering:

1. High-value transactions make it easy to conceal large sums.

A single property purchase can legitimize millions in illicit funds.

2. Lower oversight compared to banking.

Transactions often involve multiple intermediaries—agents, brokers, developers—making origin-of-funds verification challenging.

3. Ownership can be disguised.

Shell companies, third-party buyers, and layered ownership structures make beneficial ownership harder to identify.

4. Once assets are converted into property, tracing funds becomes difficult.

Criminals take advantage of this complexity to integrate illegal funds into the legitimate economy.

AML breaches in real estate do more than create financial risks—they distort property prices, undermine public trust, and weaken regulatory integrity. This is why regulators demand stronger verification, documentation, and reporting standards in 2025.

Risk-Based Approach (RBA): A Core Requirement for DNFBPs in 2025

In line with FATF guidelines, UAE businesses must implement a Risk-Based Approach to AML compliance. The RBA ensures that companies focus their resources where risks are highest rather than applying uniform measures to all transactions.

Key Elements of the RBA:

• Identify client risk levels (low, medium, high).

• Assess transaction purpose and complexity.

• Apply Enhanced Due Diligence for high-risk cases.

• Continuously monitor ongoing business relationships.

• Document the rationale behind every risk-related decision.

For DNFBPs, this is now a non-negotiable requirement. Many businesses rely on AML specialists and accounting firms to design compliant RBA frameworks tailored to their operational structure.

AML Requirements for Real Estate, Jewellery & Legal Sectors in 2025

AML expectations differ slightly across each DNFBP sector but share core pillars: KYC, verification, monitoring, documentation, and reporting.

1. AML Requirements for Real Estate Firms

Real estate companies must follow strict compliance rules, including:

Customer Due Diligence (CDD)

• Identify buyers and sellers.

• Confirm ultimate beneficial owner (UBO).

• Validate sources of funds.

Transaction Monitoring

Agents must review:

• Unusual cash purchases

• Third-party transactions

• Offshore transfers

• Over- or under-valued property deals

goAML Reporting

STRs must be filed immediately upon detecting suspicious activity.

2. AML Requirements for Jewellery & Precious Metals Traders

The jewellery sector is classified as high-risk due to frequent cash transactions and the portability of high-value items.

Mandatory compliance actions include:

• Verifying customer identity for all high-value purchases

• Reporting cash transactions above regulatory thresholds

• Monitoring repeated or suspicious purchases

• Maintaining detailed invoices, receipts, and client records

Jewellery firms must be exceptionally vigilant about customers attempting to buy items using funds with unclear origins.

3. AML Requirements for Legal Professionals

Lawyers play a key role in forming companies, transferring assets, and managing client funds—all areas vulnerable to money laundering.

Legal firms must comply with:

Enhanced Due Diligence (EDD)

Especially when:

• Structuring complex corporate entities

• Handling real estate transactions

• Managing funds on behalf of clients

Record-Keeping Standards

Legal professionals must keep:

• Engagement letters

• Client onboarding files

• Transactional documents

• Advice logs

Suspicious Reporting Obligations

Lawyers must file STRs through goAML without informing the client (no tipping-off).

The Supervisory Landscape: Who Regulates DNFBPs in the UAE?

UAE DNFBPs fall under the oversight of the AMLD (Anti–Money Laundering & Counter-Terrorism Financing Supervision Department), established under the Central Bank of the UAE. Their growing efforts since 2020 aim to strengthen compliance across:

• Real estate companies

• Legal firms

• Jewellery & precious metals traders

• Accounting and auditing firms

Authorities are particularly strict in emerging markets, where AML awareness is still developing. Businesses below compliance standards face penalties, inspections, and even license suspension.

Practical AML Steps DNFBPs Should Take in 2025

1. Create structured AML checklists for onboarding & verification

This ensures consistency in KYC and documentation.

2. Adopt digital tools to flag suspicious behavior

Technology helps detect patterns that manual reviews may miss.

3. Provide frequent staff training

Employees must stay informed of evolving laws and reporting obligations.

4. Establish strict internal escalation procedures

Clear workflows ensure suspicious activities reach the compliance officer quickly.

5. Conduct periodic AML audits

External audits from firms like Swenta validate that the process meets regulatory standards.

Why Accounting Firms Are Essential for DNFBP AML Compliance

DNFBPs face complex regulatory expectations, and accounting firms offer expertise that simplifies compliance:

• Develop industry-specific AML policies

• Conduct risk assessments & RBA implementation

• Review & update KYC forms

• Handle goAML registrations & ongoing reporting

• Maintain compliant record-keeping systems

• Train staff to prevent violations

• Prepare businesses for AML inspections

With regulatory pressure increasing each year, DNFBPs who rely on professional AML support significantly reduce their exposure to penalties and compliance gaps.

In 2025, AML compliance is a central requirement for real estate, jewellery, and legal firms operating in the UAE. Maintaining strong controls, monitoring customer behavior, documenting due diligence, and reporting suspicious activity promptly are vital for regulatory compliance and business integrity.

Partnering with accounting and audit specialists like Swenta ensures businesses meet UAE’s AML standards without operational disruption—protecting them from penalties, financial crime risks, and reputational damage.