As the UAE strengthens its AML/CFT framework in 2025, regulators are paying unprecedented attention to high-risk sectors, particularly Designated Non-Financial Businesses and Professions (DNFBPs). These include real estate brokers, jewellery traders, legal professionals, corporate service providers, auditors, and accounting firms.

With tighter enforcement, more inspections, and increasing expectations from supervisory authorities, accountants now play a critical role in ensuring businesses stay compliant. For firms like Swenta, understanding these regulatory shifts is essential for guiding clients safely through a rapidly evolving compliance landscape.

Why the UAE Is Increasing Focus on High-Risk Sectors

The UAE’s economic growth and global connectivity make it attractive for legitimate business—but also attractive for financial criminals. High-risk DNFBPs offer opportunities for money laundering due to transaction complexity, high-value assets, and sometimes fragmented compliance systems.

Among these sectors, real estate remains one of the most closely monitored areas.

Why Real Estate Is a Major Target for Money Laundering

Criminals favor real estate for several key reasons:

1. High-Value Assets Allow Large Money Movements

A single property deal can obscure millions in illicit funds.

2. Lower Historic Regulation Compared to Banking

Although improved today, the sector previously allowed anonymous ownership and unverified transactions.

3. Complex Ownership Structures Enable Hiding Beneficial Owners

Shell companies, proxy buyers, and layered transfers make tracing ownership difficult.

4. Converted Assets Are Hard to Seize or Reverse

Once funds become real estate, authorities face obstacles in identifying and recovering illegal gains.

The impact is not only financial—it destabilizes property markets, harms communities, and undermines regulatory trust.

Risk-Based Approach (RBA): The Foundation of 2025 AML Compliance

In 2025, the UAE continues enforcing the Risk-Based Approach, aligned with FATF guidelines. This means DNFBPs must:

• Identify ML/TF risks unique to their operations

• Assess clients and transactions based on risk levels

• Apply stronger due diligence for high-risk scenarios

• Maintain detailed evidence of how risks were managed

The RBA allows regulators and businesses to focus resources where they matter most.

For accountants, RBA integration into internal controls, bookkeeping, and documentation is becoming mandatory—not optional.

Key AML Responsibilities for High-Risk Sector Professionals

To comply with the UAE’s 2025 expectations, real estate firms, jewellers, legal practices, and corporate service providers must strengthen:

1. Know Your Customer (KYC) & Beneficial Ownership Verification

Identity details must be verified, validated, and documented—including the true economic owner behind every transaction.

2. Transaction Risk Review

Accountants must help determine:

• Why a transaction is taking place

• Whether pricing aligns with market values

• Whether fund sources make sense

Red flags include unusual complexity, offshore transfers, unexplained cash flows, or mismatched financial profiles.

3. Source of Funds & Source of Wealth Evaluation

High-risk clients require detailed evidence of fund origins.

4. Ongoing Monitoring

Long-term clients must be observed for:

• Abrupt changes in transaction patterns

• New beneficiaries or intermediaries

• Shifts in business structure

• Financial inconsistencies

5. Professional Support from AML Specialists

Many DNFBPs lack internal compliance systems. Accounting firms like Swenta provide essential support, including:

• AML policy creation

• Risk assessments

• goAML registrations and reporting

• Staff training

• Compliance audits

• Documentation frameworks

Role of Supervisors & Increased Enforcement in 2025

The AMLD under the Central Bank of the UAE continues to expand its inspections across all licensed DNFBPs. Their efforts include:

• Data-driven risk profiling

• Surprise inspections

• Reviewing internal AML manuals

• Validating beneficial ownership records

• Penalty issuance for non-compliance

• Mandatory corrective action plans

Sectors with weak AML maturity are receiving additional scrutiny.

Challenges in Emerging or Underregulated Markets

New DNFBPs entering the UAE market often struggle with:

• Lack of AML expertise

• Poor documentation habits

• Minimal training

• Manual processes

• Inconsistent client screening

These gaps make them increasingly vulnerable to regulatory penalties in 2025.

How Accountants Can Support High-Risk Sector Compliance

Accountants are now expected to take a proactive role, including:

✔ Standardizing Client Due Diligence (CDD) Checklists

Ensuring all required documents, validations, and risk indicators are consistently collected.

✔ Integrating Technology for Screening & Monitoring

Automated systems help detect sanctions, PEP connections, suspicious patterns, and beneficial ownership anomalies.

✔ Conducting Internal AML Reviews & Gap Assessments

Ensures processes meet 2025 regulatory expectations.

✔ Training Client Staff & Building Awareness

Employees must understand AML risks within their specific business activities.

✔ Providing RBA-Aligned Documentation & Financial Insight

Accountants help ensure business records align with AML requirements, strengthening transparency and governance.

Practical Steps Companies Should Take Now

High-risk sectors should:

• Develop sector-specific AML policies

• Map client journeys to risk indicators

• Create transaction documentation templates

• Maintain updated beneficial ownership registers

• Store all AML records for at least 5 years

• Conduct annual AML audits

• Seek ongoing support from accounting & AML experts

By implementing these measures, businesses significantly reduce regulatory and financial exposure.

The UAE’s intensified supervision means DNFBPs cannot afford weak processes or incomplete records. For accountants, this shift presents both responsibility and opportunity—professionals who understand the new risk landscape can guide businesses toward resilience, accuracy, and regulatory confidence.

With expert support from firms like Swenta, companies in high-risk sectors can strengthen compliance frameworks and operate safely in a heavily monitored environment.