The UAE has strengthened its fight against money laundering and terrorist financing with updated AML/CFT regulations. These new changes are aligned with global FATF standards and are designed to protect the economy, improve transparency, and ensure that businesses follow stricter due diligence practices.

Whether you operate in real estate, trading, e-commerce, finance, or a designated non-financial business sector (DNFBP), these new requirements apply to you. Understanding them is crucial—not just to avoid penalties, but to build long-term compliance and protect your business reputation.

Why the Changes?

The UAE continues to evolve into a global business hub, and with this rapid growth comes increased financial risk. Criminals target sectors with high-value transactions or minimal regulatory oversight. The updated AML/CFT law aims to close these gaps and ensure stronger monitoring, reporting, and verification mechanisms across all industries.

Why Real Estate Is a Major Target for Crime

Real estate remains one of the most vulnerable sectors for money laundering worldwide. Criminals prefer it because:

• High-value transactions: Large sums can be transferred in a single purchase.

• Lower regulatory restrictions compared to banks: Making ownership structures easier to disguise.

• Assets become harder to trace once purchased: Properties retain value and offer a safe place to hide illicit funds.

In several countries, the impact of illegal transactions in real estate has already inflated property values—making housing unaffordable and damaging communities. This highlights why tighter supervision in this sector is non-negotiable.

Introducing the Risk-Based Approach (RBA) — A Core Focus of the Updated Law

One of the biggest shifts in the new regulations is the emphasis on a Risk-Based Approach.

Instead of applying the same rules to every transaction, RBA requires businesses to:

• Identify where the highest risk exists

• Apply stricter controls where risk is elevated

• Reduce unnecessary checks on low-risk sectors and clients

FATF guidelines state that all regulated entities—including brokers, real estate agents, accountants, tax advisors, and company formation agents—must assess their exposure to money laundering and terrorist financing risks.

Implementing this approach helps businesses operate efficiently while ensuring compliance.

Key Responsibilities for Businesses Under the Updated AML/CFT Law

The new guidelines introduce more detailed compliance requirements. Businesses now need to take these critical steps:

1️⃣ KYC (Know Your Customer) Verification

All businesses must verify the true identity of clients—including the beneficial owner, not just the person signing the paperwork.

This includes:

• Valid identification

• Proof of ownership structure (if dealing with companies)

• Screening against sanctions and watchlists

2️⃣ Understand the Transaction Purpose

Unusual transaction behavior may be a red flag. Professionals must ask:

• Why is the client transacting?

• Is the price reasonable for current market conditions?

• Is the deal unusually complex?

If something feels suspicious, enhanced checks are required.

3️⃣ Source of Funds Verification

Cash transactions, offshore transfers, cryptocurrency payments, and unexplained income sources now require deeper scrutiny. Businesses must document attempts to validate fund origins.

4️⃣ Continuous Monitoring

Compliance is no longer a one-time KYC step.

Businesses must:

• Track ongoing client behavior

• Update verification documents periodically

• Flag changing transaction patterns

Ongoing monitoring is now mandatory for all regulated sectors.

5️⃣ Hiring AML Compliance Support

Many companies are now appointing:

• AML Compliance Officers

• Internal monitoring teams

• External consultants

Firms like Swenta assist businesses with registration, reporting, training, and system implementation to meet the new requirements smoothly.

Role of Supervisors and Regulators

Regulators are prioritizing awareness and enforcement. The main supervisory authority—the AMLD (Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department) under the Central Bank—continues to oversee compliance across regulated industries.

Their responsibilities include:

• Providing sector guidance

• Conducting inspections

• Taking enforcement action against non-compliant businesses

Businesses can expect stricter monitoring, more audits, and regulatory follow-ups in 2025.

Extra Focus on High-Risk or Developing Markets

Some sectors and regions are still establishing AML controls. The updated law instructs regulators to monitor:

• Newly registered companies

• Sectors with low AML awareness

• Regions with limited enforcement history

This phased approach ensures emerging markets don’t become entry points for financial crime.

Practical Ways Businesses Can Implement the Updated AML Requirements

To operate confidently under the new rules, businesses should:

✔ Create internal AML policies and checklists
✔ Train all employees, not just compliance teams
✔ Use software to flag high-risk patterns
✔ Document all compliance steps
✔ Review compliance processes regularly
✔ Seek support from AML specialists when needed

Consistency and documentation are key—because during inspections, proof matters more than intent.

The updated AML/CFT law is not just about avoiding penalties — it’s about creating a safer, transparent, and globally trusted business ecosystem.

Companies that build compliance into their workflow will:

• Build client trust

• Avoid costly fines

• Operate smoothly during audits

• Position themselves for long-term growth

If your business needs help adapting to the new AML/CFT rules or implementing a risk-based approach, firms like Swenta can support policy creation, reporting, software implementation, and staff training.