Anti Money Laundering (AML) Compliance in UAE

Money laundering is the act of concealing or changing the source of illegally obtained funds, by passing it through the financial and banking system to make it appear legitimate.

The UAE views money laundering and the financing of terrorism as threats to the security, stability, and integrity of the global economic and financial system and the society. As a result, strict compliance laws and equally harsh penalties are in place.

For Anti Money Laundering (AML) and countering the Financing of Terrorism (CFT) measures, UAE follows the Financial Action Task Force (FATF) guidelines.

What is AML Compliance in UAE?

UAE AML/CFT regulations cover various aspects of financial crime prevention, including legal frameworks, regulatory practices, and operational processes.

To ensure AML compliance, it is mandatory for businesses to register and report suspicious transactions to the relevant authorities, such as the UAE Financial Intelligence Unit (FIU).

The UAE AML/CFT regulations apply mainly to the following institutions:

• Financial Institutions: Banks, exchange houses, insurance companies, finance companies, and other financial entities.
• Designated Non-Financial Businesses and Professions (DNFBPs): Certain non-financial sectors, such as real estate, gold and precious metal trading, casinos, and professionals, such as auditors and accountants, lawyers, notaries, real estate agents and brokers, gold and precious metal traders, and other legal professionals and practitioners.
• Virtual Assets: Entities dealing with cryptocurrencies and digital assets, such as virtual asset custodians and wallet providers.

In the UAE, financial institutions and DNFBPs must register on the goAML website to ensure full compliance with AML/CFT regulations.

Key Obligations for Anti Money Laundering (AML) in UAE

With regard to anti money laundering in UAE, there are certain steps that you must take. We help you understand them in detail here:

1. Customer Due Diligence (CDD)

Companies must always verify the identities of their clients and any beneficial owners. Your business must also keep updated records of all clients and monitor all transactions for any suspicious activity.

2. Enhanced Due Diligence (EDD)

There are certain individuals who are considered ‘high-risk’, such as persons with political connections or certain jurisdictions. Your company must obtain more detailed records of ‘higher risk’ clients.

3. Suspicious Transaction Reporting (STR) and Suspicious Activity Reporting (SAR)

Suspicious activities include large, unexplained transactions, transactions involving high-risk countries, or activities that don't align with the customer's usual behaviour. Your business must report such suspicious transactions to the UAE Financial Intelligence Unit (FIU), typically via the Central Bank or other relevant authorities.

4. Record-keeping

Companies must maintain records of their transactions and client identification information for at least 5 years. This includes having all documents relating to the financial transaction, including contracts, agreements, and evidence of the client’s identity. These records must be accessible to regulatory authorities, including the Central Bank or other enforcement bodies for inspection, if necessary.

5. Internal Controls and Compliance Programs

Companies must establish internal policies, procedures, and controls to comply with AML/CFT laws. This includes having a designated compliance officer responsible for overseeing the procedures. They must also provide training to employees to ensure that they are aware of the relevant AML/CFT risks and can recognise and report suspicious activities.

6. Compliance with Sector-specific Regulations

Entities such as real estate agents, dealers of precious metals and stones, and accountants and auditors must fully comply with specific rules and regulations based on their sectors, such as maintaining transactions involving high-value properties, or reporting suspicious activities involving significant amounts of cash or high-value items.

7. Client Risk Assessment

Companies must assess the potential money laundering or terrorist financing risk associated with each client and their transactions. This assessment is based on factors such as the type of client, geographical location, nature of the business, and the complexity of the transactions. Companies must more frequently monitor clients who are deemed high-risk.

8. Reporting of Cross-Border Transfers

You must report large or unusual cross-border transfers, especially when they are out of the ordinary course of business, to the relevant authorities as part of anti money laundering efforts in UAE.

9. Cooperation with Authorities

You are obligated to cooperate fully with regulatory and law enforcement authorities in their efforts to detect and prevent money laundering and terrorism financing. This includes providing access to documents and information requested during investigations.

To meet these obligations effectively, businesses must also complete their goAML registration by submitting the required documents to the UAE FIU.

Documents Required for goAML Registration

GoAML (Go Anti-Money Laundering) is a secure digital platform developed by the United Nations Office on Drugs and Crime (UNODC) to help financial intelligence units combat money laundering, terrorist financing, and other financial crimes.

Business entities operating in UAE must submit the following documents for goAML registration:

• A copy of the company’s commercial or trade license.
• A letter from the company authorising an individual to act on its behalf for goAML registration in UAE.
• Copies of the compliance officer’s passport, Emirates ID, and resident visa.
• Phone number and email address of the compliance officer.

Procedure for goAML Registration in UAE

All Designated Non-Financial Businesses and Professions (DNFBPs) in the UAE are required to register with the Financial Intelligence Unit (FIU) through the goAML system. 

The registration involves a pre-registration and verification process to ensure compliance. Commitbiz business setup experts can help streamline the process.

Below is the step-by-step breakdown of the goAML registration process:

Step 1 - Complete the Pre-Registration Application

The first step is to fill out the SACM (Services Access Control Manager) pre-registration form. You must provide details about the business and the Money Laundering Reporting Officer (MLRO). Following which, our experts will upload all the supporting documents.

Step 2 - Temporary Registration and Verification

Upon submission, you receive a temporary registration number and a verification email from the FIU system. To proceed, you need to click on the email verification link. The supervisory authority reviews the application within 2 to 5 working days.

Step 3 - Obtain Secret Key and Setup Google Authenticator

After approval, an email OTP and SMS OTP are sent to the registered email and contact number. Our consultants will assist you in using these to generate the “Secret Key” via the Central Bank portal. By scanning the QR code or entering the secret key manually, install Google Authenticator (iOS or Android) and add the goAML account.
Note: The Authenticator generates a 6-digit code, which is valid for 30 seconds, used each time you access goAML.
Step 4 - Register the Entity

Fill and submit the entity registration form on the goAML portal using the generated credentials. The Ministry of Economy reviews the request, and once approved, issues a unique Organisation ID to the registered email.

This structured process ensures businesses are fully enrolled in the FIU’s goAML system, enabling them to meet mandatory reporting obligations and remain compliant with UAE regulations.

Commitbiz Anti-Money Laundering Service

Staying compliant with AML in UAE regulations is critical for businesses operating under the Ministry of Economy and other supervisory authorities. At Commitbiz, we provide specialised AML services in Dubai and across the UAE to help DNFBPs meet their obligations under AML laws in UAE and global FATF standards.

Our AML Compliance in UAE solutions include:

• goAML Registration in UAE - Complete support for mandatory AML registration in UAE, including preparing documentation, navigating the Financial Intelligence Unit’s (FIU) portal, and ensuring error-free onboarding for reporting suspicious transactions.
• Business-Wide Risk Assessment (EWRA) - Tailored assessments to identify, categorise, and mitigate money laundering and terrorism financing risks within your operations.
• Policy, Control and Procedure Manuals - Drafting and implementation of robust internal policies that align with anti-money laundering in UAE requirements, covering CDD, suspicious activity reporting, record-keeping, and governance.
• Training and Development Programmes - Staff training workshops to build awareness of AML compliance in UAE, detection techniques, and reporting procedures, ensuring the team stays regulator-ready.
• Screening and Suspicious Activity Reporting (SAR) - Assistance with due diligence, enhanced checks for high-risk clients, and preparing Suspicious Activity Reports in compliance with AML laws in UAE.
• Annual AML/CFT Return - Preparation and timely submission of annual AML returns to the Ministry of Economy or respective regulators to avoid fines and penalties.
• AML Annual Maintenance and Audit Packages - Independent audits, KYC/CDD services, regulatory reporting, and continuous consulting to keep your AML framework effective and up to date.
  Simplify AML Compliance in UAE with Commitbiz

Anti money laundering in UAE is a huge deal for businesses. Registering and staying AML compliant is required to avoid penalties and potential business risks. While it can be complicated to navigate the local AML regulations, Commitbiz consultants who have years of experience can help you with AML registration and compliance. Contact us today to avail our services!