Regulatory & Compliance · UAE

AML Compliance Services in the UAE

The UAE replaced its entire anti-money laundering framework in late 2025, and enforcement has never been sharper: administrative fines now run from AED 10,000 to AED 5,000,000 per violation, and supervisory inspections of accountants, real estate brokers, precious metals dealers and corporate service providers are intensifying ahead of the FATF's 2026 evaluation. Cressford Chartered Accountants builds and maintains the complete AML programme: goAML registration, risk assessment, policies, due diligence, screening, reporting and training, so the business is defensible on inspection day, not merely registered.

✓ Aligned to the 2025 AML law

✓ goAML registration handled

✓ Fixed fee, agreed in advance

Prefer to speak with us? Call +971 54 389 0111

Chartered Accountants · Dubai · UAE

Get AML compliant

Describe your business and your AML obligations, and gaps, are confirmed within one working day. Your details remain confidential.

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No obligation. Your details remain confidential.

The framework · updated for 2026

The UAE AML framework, and who it applies to

UAE anti-money laundering obligations are now anchored in Federal Decree-Law No. 10 of 2025, which replaced the 2018 law from 14 October 2025, and Cabinet Resolution No. 134 of 2025, which supplies the executive regulation from 14 December 2025. The regime expressly covers money laundering, terrorist financing and proliferation financing, and it applies well beyond banks. Alongside financial institutions, the law binds Designated Non-Financial Businesses and Professions (DNFBPs), and if the business falls in one of these categories, the full compliance programme is mandatory:

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Real estate agents and brokers

For transactions involving the purchase or sale of property, supervised federally by the Ministry of Economy and Tourism.

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Dealers in precious metals and stones

Among the most heavily inspected sectors, with additional transaction-reporting obligations on the goAML portal.

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Accountants, auditors and tax practitioners

Firms providing accounting, audit or tax services are themselves DNFBPs, a point many practices discover only at inspection.

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Corporate and trust service providers

Company formation agents and providers of registered office, nominee and related services.

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Lawyers and notaries

When executing specified client transactions, supervised by the Ministry of Justice.

Free zone businesses are not exempt: DIFC firms answer to the DFSA and ADGM firms to the FSRA, while mainland and commercial free zone companies fall under the federal supervisors. Uncertain whether the business is a DNFBP? That is the first question the assessment answers, in writing.

The obligations

What UAE AML compliance actually requires

Registration alone is not compliance. A defensible AML programme under the 2025 framework rests on eight obligations, and supervisory inspections test every one of them:

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goAML registration with the UAE Financial Intelligence Unit, mandatory for every DNFBP

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An enterprise-wide risk assessment (EWRA) documenting the business's actual ML, TF and PF exposure

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Board-approved AML, CFT and CPF policies and procedures matched to that risk

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Customer due diligence and enhanced due diligence, including UBO identification and PEP checks

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Real-time screening against UAE, UN Security Council and other applicable sanctions lists

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Suspicious transaction reporting through goAML, with no monetary threshold and a strict no-tipping-off rule

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A designated compliance officer with genuine standing, plus documented staff training

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Record keeping for at least five years, retrievable on supervisory request

The cost of getting it wrong

UAE AML penalties: the current numbers

Enforcement in the UAE is active, published and escalating. The figures that matter:

Exposure

Current position

Administrative fines

AED 10,000 to AED 5,000,000 per violation, and violations stack across a single inspection

Beyond fines

Restriction of activity, suspension of personnel, licence suspension or revocation, and publication of the penalty

Criminal exposure

Imprisonment and fines reaching AED 100,000,000 for legal persons convicted of money laundering offences

Enforcement to date

Well over AED 130 million in administrative fines imposed on DNFBPs since late 2022, with inspection volumes rising ahead of the FATF's 2026 evaluation

The pattern in published enforcement is consistent: missing goAML registration, absent or template-only risk assessments, incomplete customer files and untrained staff. Every one of those is preventable at a fraction of the fine.

Scope of service

Scope of our AML compliance service

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DNFBP status assessment and gap analysis against the 2025 framework, in writing

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goAML portal registration and UAE FIU onboarding, end to end

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Enterprise-wide risk assessment built on the business's real clients, products and channels

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AML-CFT-CPF policies, procedures, registers and SOPs, drafted for daily use, not for the shelf

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CDD, EDD, UBO and sanctions-screening workflows, with tooling recommendations where needed

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Compliance officer support, including outsourced MLRO arrangements where appropriate

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Staff and management training with the attendance evidence inspectors expect

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Ongoing advisory, annual reviews and inspection support when the supervisor calls

Policy & Procedure Development →AML-CFT-TFS Training →Inspection Assistance →

The process

How the business becomes compliant

Assess

DNFBP status is confirmed and the current position measured against every obligation of the 2025 framework.

goAML registration is completed, the risk assessment written, and the policy set drafted and board-approved.

Implement

Due diligence, screening and reporting workflows go live, with registers and file structures the team actually uses.

Train

Staff and management are trained on their specific roles, with attendance and assessment records retained.

Maintain

Annual reviews, regulatory-change updates and standing support keep the programme current and inspection-ready.

Why Cressford Chartered Accountants

Why businesses appoint Cressford Chartered Accountants for AML

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Current on the 2025 law

The framework changed entirely in late 2025; programmes citing the repealed legislation fail on inspection. Everything delivered references the law in force.

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Auditors' discipline

As a firm of chartered accountants and registered auditors, evidence, registers and reconcilable records are the native language, exactly what supervisory inspections test.

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A DNFBP itself

Accounting firms carry the same obligations, so the advice comes from a firm that runs the programme it recommends.

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Fixed fee, senior-led, Dubai-based

A fixed fee agreed in advance, senior professionals throughout. Office 2514, DAMAC Smart Heights, Barsha Heights (Tecom), Dubai.

FAQ

AML compliance questions, answered

Which businesses must comply with UAE AML law?

Financial institutions and DNFBPs: real estate agents and brokers, dealers in precious metals and stones, accountants and auditors, corporate and trust service providers, and lawyers and notaries in specified transactions. Virtual asset service providers are covered under their own supervisors.

What law governs AML in the UAE now?

Federal Decree-Law No. 10 of 2025, in force from 14 October 2025, supported by Cabinet Resolution No. 134 of 2025 from 14 December 2025. Together they replaced the 2018 framework and expressly extend to terrorist financing and proliferation financing.

Is goAML registration mandatory?

Yes, for every DNFBP. A business that is not registered on the UAE FIU's goAML portal is non-compliant from day one, and registration alone does not satisfy the remaining obligations.

What are the penalties for AML non-compliance?

Administrative fines from AED 10,000 to AED 5,000,000 per violation, alongside possible activity restrictions, licence suspension or revocation and publication. Criminal convictions carry imprisonment and fines reaching AED 100,000,000 for legal persons.

Who supervises AML compliance in the UAE?

The Ministry of Economy and Tourism supervises the main DNFBP sectors, the Ministry of Justice supervises lawyers and notaries, the Central Bank supervises financial institutions, and the DFSA and FSRA supervise DIFC and ADGM firms respectively. All suspicious transaction reports flow to the UAE FIU through goAML.

Is an off-the-shelf AML policy enough?

No. Supervisors test whether the programme reflects the business's actual risks and whether staff follow it; template documents that cite the repealed law or generic risks are a recurring finding in published penalties.

How long must AML records be kept?

At least five years from the transaction or the end of the business relationship, and they must be retrievable promptly when a supervisor asks.

Compliant, and able to prove it

A complete AML programme built to the 2025 framework, at a fixed fee agreed in advance.

Request my assessment or call +971 54 389 0111