Ahmed AbodaifPartner & Co-Founder
Key takeaways
- Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 replaced the 2018 law and its 2019 regulations.
- DNFBPs include real estate brokers and agents, dealers in precious metals and stones, accountants and auditors for certain activities, corporate service providers and now commercial gaming operators.
- Core duties: business-wide risk assessment, customer due diligence, beneficial-owner checks, sanctions screening, record keeping and goAML reporting.
- Senior management now carries clearer personal accountability for gaps in AML controls.
What changed
The UAE's anti-money-laundering framework is now Federal Decree-Law No. 10 of 2025, with Cabinet Resolution No. 134 of 2025 as its executive regulation. They replaced Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019. The risk-based approach is the same, but the new rules:
- allow money-laundering knowledge to be inferred from objective circumstances, lowering the bar for enforcement;
- place clearer responsibility on senior management to approve and oversee AML controls;
- tighten beneficial-ownership rules, including nominee shareholders and directors;
- add commercial gaming operators to the list of DNFBPs and make proliferation financing a standalone crime;
- give the Financial Intelligence Unit (FIU) power to suspend transactions and freeze funds for set periods.
Who is a DNFBP
| Business | When AML duties apply |
|---|---|
| Real estate brokers and agents | When acting in the purchase or sale of property |
| Dealers in precious metals and stones | Cash transactions of AED 55,000 or more, single or linked |
| Accountants and auditors | When preparing or carrying out transactions such as buying or selling property, managing client money or accounts, or forming and managing companies |
| Lawyers and notaries | For similar transactions on behalf of clients |
| Corporate and trust service providers | When forming companies, acting as registered office or nominee, or managing legal arrangements |
| Commercial gaming operators | Newly covered under the 2025 regulations |
Mainland and commercial free zone DNFBPs are supervised by the Ministry of Economy and Tourism; financial free zones have their own regulators.
The core obligations
- Register with your supervisor and on the FIU's goAML portal.
- Business-wide risk assessment covering customers, products, delivery channels and geography — approved by senior management.
- Policies and procedures proportionate to the business, and a named compliance officer.
- Customer due diligence (KYC) before the relationship or transaction, with enhanced due diligence for high-risk customers and politically exposed persons.
- Beneficial ownership: identify and verify who ultimately owns or controls corporate customers, and keep your own UBO register adequate, accurate and up to date.
- Sanctions screening against UAE local and UN lists, and immediate freezing and reporting of any match.
- Reporting suspicious transactions through goAML without delay, plus sector reports such as cash transaction reports for dealers in precious metals and stones.
- Record keeping of identification, transactions and reports for at least five years, and regular staff training.
Penalties and personal liability
Supervisors can impose warnings, restrictions, administrative fines that can reach millions of dirhams per violation, and licence suspension, on top of criminal penalties. Under the new law, regulators also look at whether senior managers approved the right policies, made sure they were applied and responded to the risks they knew about.
What to do now
- Update your AML policy, risk assessment and forms to cite the 2025 law and regulation.
- Re-check beneficial-ownership information for existing customers, especially nominee structures.
- Test your sanctions screening and freezing procedure.
- Make sure the compliance officer and goAML users are current and trained.
- Minute senior management's review and approval of the AML programme.
How Business Future CPA helps
We write and update AML policies and risk assessments, set up KYC and screening procedures, support goAML registration and reporting, and run independent AML reviews and staff training. See our AML, compliance and governance services.
Frequently asked questions
Which UAE law governs AML now?
Federal Decree-Law No. 10 of 2025, with Cabinet Resolution No. 134 of 2025 as its executive regulation. They replaced Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019.
Do accountants have to register on goAML?
Accountants and auditors are DNFBPs when they prepare or carry out certain transactions for clients — such as handling client money, property transactions or company formation. Firms in scope must register with their supervisor and on goAML and meet the AML obligations.
What is the cash threshold for gold and jewellery dealers?
Dealers in precious metals and stones have AML obligations, including cash transaction reporting, for cash transactions of AED 55,000 or more, whether single or linked.
Official sources: UAE Legislation portal · UAE Financial Intelligence Unit (goAML)
This guide is general information based on UAE legislation and official announcements as at the date shown. It is not tax or legal advice for your specific situation — talk to us before you act.