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AML Compliance Support in Dubai: A Practical Guide for Businesses

نوفمبر 14, 2026
  • Published: نوفمبر 14, 2026
  • Saadiyat Accounting - Gulzar Kasarathi

In late 2025, revisions were made to the UAE’s anti-money laundering regulations. Federal Decree-Law No. 10 of 2025 replaced the 2018 AML law. Cabinet Resolution No. 134 of 2025 replaced the earlier executive regulations. Business owners, finance managers and compliance officers now work under updated duties for due diligence, reporting and record keeping.

AML compliance support in Dubai covers the policies, checks and reports a business needs to meet those duties. This guide explains who must comply, what the rules require and when to bring in AML consultants in Dubai. It also covers where an accounting firm fits in.

Table of Contents

  • What Is AML Compliance Support in Dubai?
  • What Do AML Regulations in UAE Require?
  • Which Businesses Need AML Compliance Support in Dubai?
  • What Are the Core AML Compliance Obligations?
  • How Does an AML Risk Assessment Work?
  • What Are the Red Flags of Suspicious Transactions?
  • When Should a Business Hire AML Consultants in Dubai?
  • How Can an Accounting Firm Support AML Compliance?
  • Why Choose Saadiyat Accounting for AML Compliance Support in Dubai?
  • Frequently Asked Questions
  • Key Takeaways
  • Conclusion
  • Sources

What Is AML Compliance Support in Dubai?

AML compliance support in Dubai is professional help with meeting UAE anti-money laundering compliance duties. Money laundering means moving or hiding money to disguise its illegal source. The same framework covers terrorist financing and proliferation financing. 

Businesses without an in-house compliance team can use outside support to fill that gap. It can be a one-time project, such as drafting a policy before an inspection, or an ongoing service, such as quarterly reviews and staff training. The scope depends on the business’s activity, size and supervisor.

AML compliance support in Dubai usually covers:

  • AML risk assessment: a documented review of customer, geographical, product, transaction and delivery channel risk.
  • Policies and procedures: written AML policies approved by management.
  • Customer due diligence (CDD) and KYC: verifying customer identities and identifying ultimate beneficial owners.
  • Transaction monitoring: review of payments against each customer’s known profile.
  • Record keeping: customer files, transaction records and reports kept for at least five years.
  • Suspicious transaction reporting: reports filed with the UAE Financial Intelligence Unit (FIU) through goAML.
  • Staff training: awareness of red flags and escalation steps.

What Do AML Regulations in UAE Require?

The main AML regulations in UAE are Federal Decree-Law No. 10 of 2025 and its Executive Regulations, Cabinet Resolution No. 134 of 2025. Together they apply to financial institutions, designated non-financial businesses and professions (DNFBPs) and virtual asset service providers. The key points are:

  • Federal Decree-Law No. 10 of 2025: came into force on 14 October 2025 and superseded Federal Decree-Law No. 20 of 2018. 
  • Cabinet Resolution No. 134 of 2025: published in Official Gazette No. 811 on 15 November 2025, in force from 14 December 2025, and replaced Cabinet Decision No. 10 of 2019.
  • UAE FIU: receives and analyses suspicious transaction reports through goAML, a platform developed by the United Nations Office on Drugs and Crime (UNODC).
  • NAMLCFTC: the National Anti-Money Laundering and Combating Financing of Terrorism Committee sets the national strategy and coordinates national risk assessment.
  • FATF standards: the Executive Regulations follow Financial Action Task Force (FATF) standards.
  • Proliferation financing: businesses must identify, mitigate and document proliferation financing risk in their risk assessment.
  • Commercial gaming operators: now a DNFBP category.
  • Penalties: non-compliance can lead to administrative penalties, supervisory action and reputational damage. The exact consequence depends on the violation and the supervisor.

A business should confirm its own obligations with its supervisory authority or a qualified adviser.

Which Businesses Need AML Compliance Support in Dubai?

Financial institutions, DNFBPs and virtual asset service providers must follow UAE AML rules. DNFBPs include:

  • Real estate brokers and agents
  • Dealers in precious metals and stones
  • Independent accountants and auditors
  • Company and trust service providers
  • Lawyers, notaries and independent legal professionals
  • Commercial gaming operators

Supervision depends on the activity. The Ministry of Economy and Tourism (MoET) supervises real estate brokers, precious metals dealers, accountants, auditors and corporate service providers on the mainland and in commercial free zones. The Ministry of Justice supervises lawyers and notaries. The General Commercial Gaming Regulatory Authority (GCGRA) oversees and regulates commercial gaming operations.  Firms in DIFC and ADGM answer to the regulators of those financial centres, such as the Dubai Financial Services Authority (DFSA) in DIFC.

Real estate firms, corporate service providers and dealers in precious metals and stones should check how their specific activity is classified before building procedures.

What Are the Core AML Compliance Obligations?

A regulated business must put seven controls in place.

  1. Customer due diligence (CDD) and KYC verification: Verify customer identity, understand the purpose of the relationship and identify ultimate beneficial owners (UBOs). Higher-risk customers, including politically exposed persons (PEPs), need enhanced due diligence (EDD). Under the 2025 Executive Regulations, EDD includes identifying source of wealth and obtaining senior management approval.
  2. Business-wide risk assessment: Document where the business could be misused, including proliferation financing risk, and rate each risk.
  3. Transaction monitoring: Review transactions against the customer’s known profile and flag unusual activity.
  4. Suspicious transaction reporting: Report suspicious transactions and activities promptly to the UAE FIU through goAML as suspicious transaction reports (STRs) or suspicious activity reports (SARs). Designated Non-Financial Businesses and Professions (DNFBPs) are mandated to register on the goAML portal. 
  5. Record keeping: Keep customer files, transaction records, reports, risk assessments and training logs for at least five years. Records must be available on demand during an inspection.
  6. Compliance officer (MLRO): Appoint a qualified Money Laundering Reporting Officer or equivalent to supervise AML compliance, report suspicious activity and liaise with supervisors.
  7. Written policies and training: Maintain approved AML policies and train staff on them regularly.

Each control needs a documented procedure and records that can be produced on request.

How Does an AML Risk Assessment Work?

An AML risk assessment is a documented review of where a business could be used for money laundering. UAE businesses must carry out risk assessments using documented methodologies. Under the 2025 Executive Regulations, DNFBPs must also identify, mitigate and document proliferation financing risks.

The assessment looks at risks linked to:

  • Customers: customer types and their profiles.
  • Geography: the countries and locations the business deals with.
  • Products and services: services that could be used to move or hide funds.
  • Delivery channels: how the business reaches and onboards customers.

Entities must maintain records of each risk assessment and make them readily available for inspection. 

What Are the Red Flags of Suspicious Transactions?

Red flags are signs that a transaction or customer may be linked to money laundering. UAE supervisory guidance points to indicators such as:

  • Layered or complex ownership structures
  • Involvement of a politically exposed person (PEP)
  • Funding from third parties with no clear link to the customer
  • Use of virtual assets
  • Incomplete or inconsistent customer due diligence information
  • Unusual patterns that do not match the customer’s known profile
  • Adverse media about the customer

A single red flag does not prove wrongdoing. A pattern, or a flag that staff cannot explain, calls for review. Staff should record the observation and escalate it to the compliance officer promptly.

The compliance officer reports suspicious activity to the FIU through goAML. Tipping off is prohibited, so staff must not tell the customer that a report is under consideration. Each review and its outcome should be recorded, including cases where no report is filed.

When Should a Business Hire AML Consultants in Dubai?

A business should hire AML consultants in Dubai when a specific event exposes a compliance gap. Common triggers include:

  • New or updated regulations: the 2025 Decree-Law and Cabinet Resolution changed several duties.
  • A regulatory notice or warning: a supervisor has flagged a weakness.
  • An upcoming AML inspection or regulatory audit: policies, risk assessments and records must be ready for review.
  • A new business in a regulated sector: goAML registration and AML policies are needed before operations scale.
  • Unusual transactions: staff are unsure whether to escalate or report.
  • KYC verification difficulties: customer verification keeps stalling or produces inconsistent records.
  • Advice from an auditor or lawyer: an adviser has recommended stronger AML procedures.

In each case, a consultant can run an AML gap assessment against current requirements. The consultant can then draft or update policies, set up CDD and KYC procedures, and prepare regulatory reports.

How Can an Accounting Firm Support AML Compliance?

An accounting firm works with the financial records that AML reviews depend on. Saadiyat Accounting’s AML service covers four areas:

AML support areaWhat the service covers
Risk assessment and compliance reviewAML risk assessments and compliance reviews tailored to the business’s operations and industry sector
AML policy developmentAML policies and procedures with internal controls and reporting mechanisms
Transaction monitoring and due diligenceMonitoring for unusual or suspicious activity and customer identity checks for KYC requirements
Regulatory reporting and compliance supportPreparing and filing regulatory reports and keeping the AML programme current with changing regulations

An accounting firm does not replace the business’s own compliance officer. It does not give legal advice on how the law applies to a specific case. The scope of support depends on the firm’s qualifications and authorisations. A business should confirm that scope in writing before appointing any provider.

Why Choose Saadiyat Accounting for AML Compliance Support in Dubai?

Saadiyat Accounting provides Dubai-based financial solutions as a registered entity with the Federal Tax Authority (FTA). The firm was founded in January 2018 and offers AML services in Dubai and the UAE alongside audit, tax and accounting services.

  • 4,900+ businesses served and 2,900+ audits completed across Dubai, Abu Dhabi and Sharjah.
  • Qualified team: accountants, certified auditors and corporate tax specialists, led by senior tax advisor Gulzar Kasarathi.
  • Credentials: team members hold ACCA, CA and CMA qualifications.
  • Client rating: 4.9 stars on Google.
  • Industry coverage: startups, SMEs, free zone companies, e-commerce, trading, construction, healthcare clinics, hospitality, real estate and professional service firms.
  • Audit documentation: records maintained to satisfy official inspections.
  • Related services: external audit, VAT, corporate tax, excise tax, bookkeeping, payroll, backlog accounting and business setup.

Businesses can request an AML risk assessment or compliance review from Saadiyat Accounting.

Frequently Asked Questions

How does UAE law define money laundering? 

Article 2 of Federal Decree-Law No. 10 of 2025 covers a person who knows, or should reasonably suspect, that money comes from illegal activity. The offence includes converting or transferring the money to hide its source, concealing its origin, ownership or movement, and using or keeping it after receiving it. Helping someone involved in a crime avoid detection or punishment also counts.

Who counts as a politically exposed person (PEP)? 

The 2025 Executive Regulations explicitly list senior officials of political parties and persons entrusted with the management of international organisations. Members of senior management within these bodies are also covered.

What do the beneficial owner rules require? 

The 2025 Executive Regulations set more detailed ultimate beneficial owner (UBO) rules than the 2019 regulations. Companies must update UBO details within 15 working days. Bearer shares are prohibited, with a 30-day conversion period. Nominee status must be disclosed promptly.

What powers does the FIU have to freeze funds? 

The Executive Regulations allow the FIU Head to order suspensions of up to 10 working days and freezes of up to 30 days on suspected criminal funds. Under the 2019 regulations, the freezing power rested with the Central Bank Governor and applied only to Central Bank licensed financial institutions.

Is there a tipping-off exception for auditors? 

Tipping off remains prohibited. The 2025 Executive Regulations clarify limited exemptions for legal professionals and auditors. These professionals may attempt to dissuade a client from unlawful conduct without that counting as tipping off.

Key Takeaways

  • Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 form the current AML regulations in UAE.
  • DNFBPs include real estate brokers, accountants, auditors, precious metals dealers and corporate service providers.
  • Core controls are CDD and KYC, risk assessment, transaction monitoring, goAML reporting, five-year record keeping, a compliance officer and staff training.
  • An AML risk assessment must now include proliferation financing.
  • A pattern of red flags, not a single sign, should trigger a review and possible report to the FIU.
  • Inspections, regulatory notices, new regulated businesses and auditor advice are common reasons to seek AML consultants in Dubai.
  • An accounting firm can support the work but does not replace the business’s compliance officer.

Conclusion

UAE AML rules ask for documented procedures, trained staff and records that stand up to inspection. A business with a current risk assessment, clear CDD and KYC steps and organised records is better prepared for a supervisor’s review.

Saadiyat Accounting offers AML services in Dubai and across the UAE, including risk assessment, policy development, transaction monitoring and regulatory reporting support. Call 04 234 1555 or email info@accountsdubai.com to discuss your AML compliance requirements.

Sources