The UAE entered 2025 with one of the strongest Anti-Money Laundering (AML) enforcement agendas in the region. Following several years of global scrutiny and rapid economic growth, the government is now stepping up monitoring, supervision, and penalties across all sectors—especially real estate, jewellery, legal services, accountants, and other designated non-financial businesses and professions (DNFBPs).

As businesses face stricter inspections, mandatory compliance audits, deeper KYC expectations, and increased reporting obligations, preparing early is no longer optional. It’s a survival requirement.

This guide explains the 2025 AML enforcement surge, why the UAE is intensifying oversight, and how accounting firms like Swenta support companies in building strong AML systems that withstand regulatory pressure.

Why AML Enforcement Has Intensified in 2025

1. High-Value Sectors Attract Illicit Funds

Criminals continue to prefer sectors such as real estate because:

• Property allows large financial movements in one transaction

• Oversight has historically been lighter compared to banking

• Ownership can be masked through layered structures

• Converting cash into real estate makes tracing difficult

This has real societal impact. Illicit money inflates property prices, destabilises markets, and undermines fair business competition.

2. Increased Scrutiny from International Bodies

With FATF expectations tightening globally, 2025 is a year of strong compliance alignment for the UAE. Regulators are focusing on:

• Beneficial ownership transparency

• Risk-based supervision

• Cross-border transactions

• DNFBP vigilance

3. Rise in Digital Transactions

As more payments move online, criminals exploit new channels. The government now requires stricter AML monitoring, record-keeping, and reporting from all digitally-active businesses.

Understanding the Risk-Based Approach (RBA) in 2025

The risk-based approach is now the central pillar of AML regulation.

Instead of applying identical rules to every client or transaction, businesses must:

• Identify higher-risk customers

• Flag unusual behaviours early

• Apply enhanced due diligence (EDD) where necessary

• Monitor ongoing business relationships

• Maintain clear documentation and audit trails

FATF recommends that all DNFBPs evaluate and manage risks continuously—something most businesses cannot achieve without professional AML support.

This is where accounting experts, including Swenta, strengthen compliance frameworks through structured risk assessments and system design.

Why Real Estate Remains a Prime AML Target in 2025

The UAE’s booming real estate sector continues to attract illicit funds due to:

High asset value

One property purchase can hide millions of dirhams.

Flexible ownership structures

Offshore companies, nominees, and layered entities complicate identification.

Fewer historical controls than banks

Although this has changed, criminals continue exploiting gaps.

Difficulty in reversing or seizing assets

Once funds become property, tracing and recovery become highly complex.

These risks explain why 2025 regulations require:

• Deeper KYC

• Enhanced ownership verification

• Source-of-funds analysis

• Mandatory suspicious transaction reporting

• goAML accuracy and timeliness

Key Steps Businesses Must Take in 2025 to Stay Compliant

Here are the core responsibilities for all DNFBPs—real estate brokers, jewellers, corporate service providers, law firms, and accounting firms:

1. Strengthen KYC & Customer Identification Processes

Companies must verify:

• Customer identity

• Beneficial ownership (UBO)

• Purpose of the transaction

• Source of funds

• Whether the customer is a PEP (Politically Exposed Person)

Failing to verify true ownership is one of the fastest ways to incur penalties in 2025.

2. Understand and Assess Each Transaction

Businesses must identify:

• Unusually structured deals

• Transactions priced far above or below market value

• Deals with unclear commercial purpose

• Offshore funds with no transparency

These are key warning signs of money laundering.

3. Follow the Money Trail

Regulators expect businesses to question:

• Where funds originate

• How payments are being made

• Whether cash is used excessively

• If offshore transfers involve high-risk jurisdictions

Clear documentation is essential.

4. Monitor Ongoing Business Relationships

AML compliance isn’t a one-time exercise. Companies must:

• Re-verify customer information

• Watch for behavioral changes

• Conduct periodic due diligence reviews

• Flag suspicious activity

5. Seek Professional AML Guidance

Most DNFBPs do not have internal compliance teams with AML expertise. For this reason, accounting firms like Swenta help businesses by:

• Reviewing AML policies and procedures

• Designing risk assessments

• Implementing KYC frameworks

• Preparing businesses for regulatory inspections

• Managing goAML registration and reporting

• Conducting AML audits and gap assessments

Professional support dramatically reduces the risk of fines, which in 2025 are expected to increase both in frequency and severity.

How Regulators Are Responding in 2025

The UAE’s AMLD and other supervisory authorities have strengthened enforcement through:

• Surprise inspections

• Mandatory AML training requirements

• goAML reporting audits

• UBO verification reviews

• Sector-specific AML guidance updates

• Penalties for late or incorrect reporting

Regulators are particularly focused on sectors with previously low AML literacy. This includes emerging businesses, new real estate agencies, small jewellers, and firms entering corporate service activities for the first time.

What Your Business Should Do Now

To avoid penalties during the 2025 enforcement phase, companies should:

✓ Update AML manuals and compliance frameworks
✓ Ensure all staff receive formal AML training
✓ Document risk assessments and customer reviews
✓ Maintain complete transaction logs and evidence
✓ Validate beneficial owner information
✓ Automate goAML reporting where possible
✓ Conduct a third-party AML readiness audit

Businesses that invest in compliance now will avoid costly disruptions later.

The UAE is committed to protecting its financial systems and business environment. As a result, AML compliance standards in 2025 are stronger and more actively enforced than ever.

With expert support from accounting and AML specialists such as Swenta, businesses can confidently meet regulatory expectations, avoid penalties, and build sustainable compliance systems for long-term success.