UAE AML law (Federal Decree-Law 20/2018) requires DNFBPs (accountants, lawyers, real estate agents, gold dealers, trust and company service providers) to: register on goAML; conduct KYC/CDD on clients; file Suspicious Transaction Reports (STRs); and appoint a Compliance Officer. Penalties for non-compliance: up to AED 1 million per violation.
Who is a DNFBP in UAE
Designated Non-Financial Businesses and Professions (DNFBPs) subject to UAE AML obligations include:
- Real estate agents and brokers: Any person who buys or sells real estate on behalf of a client.
- Dealers in precious metals and stones: Gold, diamond, and jewellery retailers and dealers — cash transactions above AED 55,000.
- Auditors, accountants, and external advisors: When acting for a client in transactions involving buying/selling businesses, managing client funds, or creating company structures.
- Lawyers, notaries, and legal professionals: When acting in financial or real estate transactions on behalf of clients.
- Trust and Company Service Providers (TCSPs): Any person who provides registered office addresses, nominee director/shareholder services, or company formation.
UAE AML obligations for DNFBPs
Register on goAML
All DNFBPs must register their business and the appointed Compliance Officer on the UAE Financial Intelligence Unit’s goAML portal (amlcft.ae). Registration is mandatory before conducting any relevant activity.
Appoint a Compliance Officer
Designate a senior employee as the AML Compliance Officer. This person is responsible for AML policies, staff training, suspicious activity monitoring, and STR filing. The Compliance Officer must be registered on goAML.
Conduct KYC/CDD on all new clients
Before onboarding: verify client identity (passport/Emirates ID), verify beneficial ownership (for corporate clients), understand source of funds, and assess risk level. Higher-risk clients require Enhanced Due Diligence (EDD).
File Suspicious Transaction Reports (STRs)
If at any point a transaction or activity is suspected to involve money laundering or terrorist financing, file an STR on goAML within 35 days. Tip-off to the client (tipping off) is a criminal offence.
Maintain records
All KYC documents, transaction records, and STRs must be maintained for 5 years from the end of the business relationship. AML records are subject to FIU inspection.
UAE AML penalties
- Failure to register on goAML: Administrative fine up to AED 100,000.
- Failure to conduct CDD: Fine up to AED 1 million per violation.
- Failure to file an STR: Criminal prosecution — up to 3 years imprisonment and AED 1 million fine.
- Tipping off: Informing a client that an STR has been or is being filed is a criminal offence — up to 2 years imprisonment.
DNFBP compliance not in place yet?
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Frequently asked questions
Do UAE accountants have AML obligations?+
Yes — when acting as a DNFBP. Accountants who help clients form companies, manage client funds, or advise on buying/selling businesses are subject to AML obligations: goAML registration, KYC/CDD on clients, and STR filing when suspicious activity is identified.
What is goAML and how do UAE businesses register?+
goAML is the UAE Financial Intelligence Unit’s (CBUAE) web portal for AML reporting. DNFBPs register at goaml.uae.gov.ae — creating a business account and registering the AML Compliance Officer. Registration is free but mandatory.
What is Enhanced Due Diligence in UAE AML?+
EDD is applied to higher-risk clients: Politically Exposed Persons (PEPs), clients from high-risk jurisdictions (FATF grey/black list countries), complex ownership structures, and clients where the source of wealth is unclear. EDD requires additional verification — senior management approval, source of funds documentation, and more frequent monitoring.
What is a Suspicious Transaction Report in UAE?+
An STR is a confidential report filed on goAML when a DNFBP suspects that a transaction or activity involves money laundering, terrorist financing, or proceeds of crime. The report is reviewed by the UAE FIU. Filing an STR is mandatory — failure to file when there are reasonable grounds for suspicion is a criminal offence.