The UAE Anti Money Laundry Regulations applies on the regulated sectors referred to as Designated non-Financial Businesses and Professions (“DNFBPs”) and include:

  1. Real Estate Brokers and Agents

  2. Dealers in of Precious Metals and Stones

  3. Independent Accountants (Auditors), and lawyers, notaries, and other independent legal professionals

  4. Company Services Providers


Do I Fall Under the DNFBPs Scope?

The following will help you in identifying if you or your business fall under the scope of the DNFBPs:

Real Estate Brokers and Agents

Brokers and real estate agents when they conclude operations for the benefit of their customers with respect to the purchase and sale of real estate.

Dealers in of Precious Metals

and Stones

Those involved in the production of precious metals or precious stones; an intermediate buyer or broker; precious stone cutter and polisher; precious metal refiner; and/or a jewelry manufacturer. These include gold, silver, platinum, diamonds and others.


Further, dealers in precious metals and precious stones in carrying out any single transaction or several transactions that appear to be interrelated or equal to more than AED 55,000.

Independent Accountants (Auditors)

Lawyers, notaries, and other independent legal professionals and independent accountants, when preparing, conducting, or executing financial transactions for their customers in respect of the following activities:

  1. Purchase and sale of real estate.

  2. Management of funds owned by the Customer.

  3. Management of bank accounts, saving accounts or securities accounts.

  4. Organizing contributions for the establishment, operation, or management of companies.

  5. Creating, operating, or managing legal persons or Legal Arrangements.

  6. Selling and buying commercial entities.

Company Services Providers

Providers of corporate services and trusts upon performing or executing a transaction on the behalf of their customers in respect of the following activities:

  1. Acting as an agent in the creation or establishment of legal persons.

  2. Working as or equipping another person to serve as director or secretary of a company, as a partner or in a similar position in a legal person.

  3. Providing a registered office, work address, residence, correspondence address or administrative address of a legal person or Legal Arrangement.

  4. Performing work or equipping another person to act as a trustee for a direct Trust or to perform a similar function in favor of another form of Legal Arrangement.

  5. Working or equipping another person to act as a nominal shareholder in favor of another person.


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Appointment of Compliance Office

We have identified now if you are within or not within the scope of the UAE Anti Money Laundry Regulations. Now comes compliance; and the following is required from you:

Appointing a Compliance Officer

You shall appoint a natural person who shall be responsible for the compliance of the UAE Anti Money Laundry Regulation. The Compliance Officer shall:

  1. Be a natural person who is employed by the company or is appointed.

  2. Have the appropriate competence and experience to provide all relevant data, procedures and obligations that are enforceable to fulfill the requirements of the AML/CFT regulations.

  3. Perform due diligence measures including identifying and verifying clients beneficiary owners’ information

  4. Report suspicious transactions

  5. Maintain and keep required information and data

  6. Providing clients’ information and data to the competent authorities upon request


Here is a template of a letter appointing you Compliance Officer:

Performing Due Diligence Measures

This means identifying or verifying the information of customers/clients or the beneficiary owner—including whether they are a natural or legal person or a legal arrangement; the nature of his work; the purpose of the business relationship; and the ownership structure and the control over it.


Reporting Suspicious Transactions

In case of suspicious transactions, submit required forms and reports to the Financial Intelligence Units through the goAML system.


Registration in the Automatic Reporting System for Sanction Lists

Designated non-Financial Businesses and Professions must register in the automatic reporting system for sanctions lists to instantly obtain updated lists of targeted financial sanctions from the United Nations Security Council’s consolidated sanctions lists and domestic terrorism lists.


Identify and Report Suspicious Transactions


Maintain Adequate Records of all the Previous Points


If you have any questions on the compliance requirements and procedures, feel free to reach out to our Partner on:



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The UAE Anti Money Laundry regulations impose various penalties for the different non-compliance acts. The best way to shed light on the penalties is to attach an extract of the penalties’ articles here:

Penailties for UAE Money Laundery

Please take note the severity of the penalties. They are avoidable and so follow the and implement the requirements to avoid unnecessary costs and business interruption.



We are in the process in developing a generic UAE Anti Money Laundry Policy to offer it as a guidance and starting point for your business. Message us the word goAML Policy to share it with you once it is ready.


Further Questions? Do send us an email and we will get back to you as soon as possible.

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