AML & goAML Compliance for UAE Businesses (DNFBPs)

Who this applies to

UAE anti-money-laundering law places specific obligations on Designated Non-Financial Businesses and Professions (DNFBPs). The main categories are:

Real estate brokers and agents involved in property transactions
Dealers in precious metals and gemstones above defined transaction values
Auditors and accountants in independent practice
Company service providers — those forming companies, providing registered addresses, or acting as directors or nominee shareholders for others
Lawyers and notaries when carrying out certain defined transactions for clients

Note on the last category: businesses that set up companies for third parties fall within the Trust and Company Service Provider definition. That includes consultancies like ours — which is why we treat this as a compliance discipline we live with, not a service we merely sell.

Core obligations

Obligation	In practice
goAML registration	Register on the national reporting portal — mandatory, not optional
Customer due diligence	Identify and verify clients and ultimate beneficial owners before acting
Risk assessment	Document a business-wide risk assessment and risk-based procedures
Policies and controls	Written AML policy, internal controls, and a designated compliance officer
Suspicious transaction reporting	File reports through goAML when the thresholds for suspicion are met
Record keeping	Retain due-diligence records for the required period
Training	Staff trained to recognise and escalate red flags

Penalties

Administrative penalties for AML breaches in the UAE are substantial — commonly cited from AED 50,000 into the millions per violation depending on severity, alongside the risk of licence action. The framework was reinforced by further federal legislation in 2025, and supervisory attention has increased rather than diminished.

How we help

goAML registration, a documented risk assessment, an AML policy that reflects what your business actually does rather than a downloaded template, customer due-diligence procedures your team can follow, and periodic review as your business and the rules change.

Frequently asked questions

For businesses falling within the DNFBP categories, yes. It is a legal requirement rather than a best-practice recommendation, and supervisors do check.

Not simply for trading. The obligation attaches to the defined DNFBP categories — real estate brokers, dealers in precious metals and stones, auditors and accountants, company service providers, and lawyers or notaries performing certain transactions. If you are unsure whether your activity falls in scope, that is worth checking rather than assuming.

The sensible course is to regularise promptly rather than wait to be found. Penalties are significant and supervisory scrutiny has increased. We can assess whether you are in scope and, if so, complete registration and put the underlying policies in place.

AML & goAML Compliance