Anti-Money Laundering (AML) compliance in the UAE has undergone a fundamental shift. In 2025, AML is no longer viewed as a task handled only by compliance officers or risk teams. Instead, it has become a board-level responsibility, with directors and senior management expected to actively oversee, question, and guide AML frameworks.

Regulators are making it clear: when AML failures occur, accountability does not stop at the compliance department—it reaches the boardroom.

This article explains why AML governance has moved to the top of corporate agendas in the UAE and what boards must do to meet rising regulatory expectations.

The Changing AML Landscape in the UAE

Over the past few years, the UAE has significantly strengthened its AML/CFT framework to align with global standards set by the Financial Action Task Force (FATF). Enforcement actions, supervisory inspections, and regulatory guidance now emphasize governance, accountability, and effectiveness, not just policy existence.

As a result, boards are expected to:

• Understand their company’s AML risk exposure

• Approve and oversee AML frameworks

• Ensure sufficient resources and authority for compliance functions

• Be informed of material AML risks and incidents

AML failures are increasingly treated as corporate governance failures, not operational oversights.

Why Regulators Are Focusing on Boards and Senior Management

Criminal networks adapt quickly, exploiting weak oversight, poor controls, and fragmented decision-making. Regulators have learned that AML systems fail most often when:

• Leadership is disengaged

• Risk assessments are superficial

• Compliance teams lack authority

• Red flags are ignored due to commercial pressure

By placing responsibility at board level, regulators aim to ensure that business growth never overrides compliance obligations.

Why Certain Sectors—Including Real Estate—Remain High on the Risk Radar

While AML governance applies across all sectors, regulators continue to pay close attention to industries with higher exposure to financial crime.

Real estate remains a key example because:

• Transactions involve high-value assets

• Ownership structures can be layered or opaque

• Third-party intermediaries are common

• Once funds are invested in property, tracing becomes difficult

Globally, unchecked money laundering through real estate has inflated property prices, displaced local communities, and weakened financial integrity. These risks reinforce why boards must understand sector-specific AML exposure, not just generic compliance rules.

The Risk-Based Approach: A Governance Imperative

A risk-based approach (RBA) is the cornerstone of modern AML frameworks—and boards are ultimately responsible for ensuring it is applied correctly.

Rather than treating all clients and transactions equally, an RBA requires companies to:

• Identify high-risk products, customers, and jurisdictions

• Apply enhanced controls where risks are elevated

• Allocate resources proportionately

• Regularly review and update risk assessments

Boards must approve the risk appetite and ensure management can demonstrate how the RBA operates in practice—not just on paper.

Board Expectations Under FATF-Aligned Standards

Under FATF principles, senior management and boards are expected to:

• Approve AML policies and risk assessments

• Oversee the implementation of AML controls

• Ensure independence of the compliance function

• Receive regular AML reporting

• Take corrective action when weaknesses are identified

In 2025, “lack of awareness” is no longer considered an acceptable defense.

Key AML Responsibilities Boards Can No Longer Delegate Away

1. Oversight of KYC and Beneficial Ownership Controls

Boards must ensure that management has robust processes to:

• Verify customer identities

• Identify ultimate beneficial owners (UBOs)

• Detect nominee arrangements or shell companies

Weak KYC remains one of the most common causes of regulatory penalties.

2. Monitoring Source of Funds and Transaction Behavior

Following the money is a critical board-level concern. Red flags include:

• Unexplained cash transactions

• Payments from unrelated third parties

• Offshore or high-risk jurisdiction involvement

• Complex or illogical deal structures

Boards should receive summaries of material risks and suspicious activity trends—not just compliance statistics.

3. Ongoing Monitoring, Not One-Time Approval

AML compliance is continuous. Boards must ensure systems are in place for:

• Ongoing transaction monitoring

• Periodic client reviews

• Escalation of unusual patterns

Approving a client relationship once is no longer sufficient.

Role of Supervisors and Regulators in Driving Board Accountability

In the UAE, AML/CFT supervision is overseen 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:

• Expanded supervisory reach

• Increased inspections across sectors

• Focused on governance and control effectiveness

Regulators now assess whether boards actively engage with AML risks—or merely delegate them.

Special Attention on Emerging and Underdeveloped Markets

Markets or sectors with lower AML maturity receive enhanced scrutiny, particularly where:

• New firms enter high-risk industries

• AML awareness is limited

• Internal controls are still developing

Boards operating in such environments must demonstrate stronger oversight and faster remediation of gaps.

How Boards Can Strengthen AML Governance in 2025

Practical steps boards should take include:

• Reviewing and approving enterprise-wide AML risk assessments

• Ensuring compliance teams have independence and authority

• Requesting clear, risk-focused AML reporting

• Supporting regular AML training for management

• Engaging external AML advisors for independent reviews

Professional firms like Swenta, operating in audit, accounting, and compliance advisory, often support boards by providing independent AML assessments and governance-focused guidance without disrupting operations.

Why AML Is Now a Leadership Issue, Not Just a Compliance Issue

AML failures can lead to:

• Regulatory penalties

• Loss of banking relationships

• Reputational damage

• Business disruption

Boards that actively engage in AML governance protect not only compliance—but long-term business sustainability.

In 2025, AML compliance in the UAE has clearly moved into the boardroom. Regulators expect directors to understand risks, challenge assumptions, and ensure AML frameworks work in practice.

Companies whose boards treat AML as a strategic governance responsibility will be far better positioned to navigate regulatory scrutiny, maintain stakeholder trust, and grow sustainably.

Those that don’t risk learning this lesson the hard way.