The UAE has significantly strengthened its anti-money laundering (AML) framework over the last few years. In 2025, Designated Non-Financial Businesses and Professions (DNFBPs) are under sharper regulatory focus than ever before. This includes real estate brokers, developers, dealers in precious metals and stones, lawyers, auditors, accountants, and company service providers.

The reason is clear: DNFBPs sit at critical points where illicit money can quietly enter the legitimate economy. Regulators now expect these businesses to act as the first line of defense, not passive participants.

This article explains why AML scrutiny on DNFBPs has intensified, why real estate remains a prime target, and how a risk-based approach (RBA) is central to compliance expectations in the UAE in 2025.

Why DNFBPs Are Under Greater AML Pressure in 2025

Global watchdogs such as the Financial Action Task Force (FATF) have consistently highlighted DNFBPs as vulnerable gateways for money laundering and terrorist financing. Unlike banks, DNFBPs often handle high-value transactions with fewer historical controls.

In response, the UAE has aligned its regulatory approach with international best practices by:

• Expanding AML obligations for DNFBPs

• Increasing on-site inspections and thematic reviews

• Imposing stricter penalties for weak controls

• Demanding demonstrable, documented risk assessments

By 2025, tick-box compliance is no longer acceptable. Authorities expect DNFBPs to understand why risks exist and how they are being mitigated.

Why Real Estate Continues to Be a High-Risk Sector

Among all DNFBPs, real estate remains one of the most heavily scrutinized sectors.

Criminals are drawn to real estate for several structural reasons:

1. High-Value Transactions

Property deals allow large sums of money to be moved in a single transaction, making them ideal for laundering proceeds of crime.

2. Ownership Complexity

Use of shell companies, nominees, or third-party buyers can obscure the true beneficial owner, especially when due diligence is weak.

3. Asset Conversion

Once funds are invested in property, they become harder to trace or confiscate, particularly if resold or leased.

4. Social and Economic Impact

In multiple jurisdictions, illicit money in real estate has artificially inflated property prices, pushing housing beyond the reach of ordinary residents. This undermines trust, distorts markets, and damages communities.

Because of these risks, real estate DNFBPs are expected to apply enhanced scrutiny, not just basic checks.

Understanding the Risk-Based Approach (RBA)

A risk-based approach means allocating compliance resources according to risk — not treating every client or transaction the same.

Under FATF standards, DNFBPs must:

• Identify money laundering and terrorist financing risks

• Assess their likelihood and impact

• Apply controls proportional to those risks

High-risk transactions require enhanced due diligence (EDD), while lower-risk activities may follow standard procedures.

In practice, this approach allows businesses to remain commercially efficient while staying compliant.

Key AML Expectations for Real Estate and Other DNFBPs

To meet regulatory expectations in 2025, DNFBPs must demonstrate active risk management, not passive form-filling.

1. Robust Know Your Customer (KYC)

DNFBPs must verify:

• Identity of buyers and sellers

• Ultimate Beneficial Owners (UBOs)

• Legal structures behind corporate clients

Identifying who truly controls the funds is non-negotiable.

2. Understanding the Transaction Logic

Red flags include:

• Deals that are unusually complex

• Prices significantly above or below market value

• Clients unable to clearly explain the transaction purpose

If the transaction does not make commercial sense, it deserves closer review.

3. Source of Funds Verification

Businesses should assess:

• Whether funds originate from high-risk jurisdictions

• Use of large cash components

• Frequent offshore transfers without economic rationale

Suspicious funding patterns should trigger enhanced checks or reporting.

4. Ongoing Monitoring

AML compliance does not end after onboarding. DNFBPs must:

• Monitor repeat clients

• Track changes in transaction behavior

• Update risk profiles regularly

This is especially critical for long-term business relationships.

The Role of Supervisors and Regulators in the UAE

DNFBPs are not expected to manage AML risk alone. Regulators play a central role in setting expectations and enforcing compliance.

In the UAE, AML/CFT supervision is overseen by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD), operating under the Central Bank of the United Arab Emirates (CBUAE).

Since 2020, the AMLD has:

• Expanded supervisory coverage across DNFBP sectors

• Issued detailed guidance and red-flag indicators

• Conducted inspections and follow-up reviews

• Strengthened enforcement actions for non-compliance

Where sectors are still maturing, regulators apply closer supervision until adequate AML capability is demonstrated.

Special Attention on Emerging or Weakly Regulated Segments

Authorities are particularly cautious with:

• Newly licensed real estate agencies

• DNFBPs with limited AML experience

• Markets with past enforcement gaps

Supervisors closely monitor these segments to prevent them from becoming safe havens for illicit funds. Capacity-building, training, and stricter oversight are common during early growth phases.

Practical Ways DNFBPs Can Strengthen AML Controls

To align with 2025 expectations, DNFBPs should focus on operational effectiveness:

• Develop clear internal AML checklists

• Maintain written risk assessments and policies

• Use technology to flag unusual patterns

• Train staff regularly on red flags and reporting

• Escalate high-risk cases consistently

• Review AML frameworks annually

Many firms also engage experienced AML advisors to ensure alignment with evolving UAE regulations and supervisory expectations.

Why AML Compliance Is Now a Strategic Business Issue

For DNFBPs, AML compliance is no longer just a regulatory burden. In 2025, it directly affects:

• Licensing continuity

• Reputation and client trust

• Banking relationships

• Exposure to fines and penalties

Firms that proactively strengthen their AML frameworks are better positioned to grow sustainably, attract quality clients, and withstand regulatory inspections.

The heightened AML scrutiny on DNFBPs in the UAE reflects a broader global shift toward outcome-driven compliance. Regulators expect businesses to understand their risks, act responsibly, and demonstrate accountability.

For real estate professionals and other DNFBPs, adopting a risk-based approach is not optional — it is the foundation of compliance in 2025.

Firms that invest early in strong AML governance, systems, and expertise will not only stay compliant but gain a long-term competitive advantage in an increasingly regulated environment.