AML law
UAE AML/CFT obligations for DNFBPs
An overview of who is covered, the duties that apply, and where groAML fits. General information, not legal advice.
Who is obliged
The UAE AML/CFT framework applies to financial institutions and to designated non-financial businesses and professions (DNFBPs). DNFBPs include real-estate brokers and agents, dealers in precious metals and stones, auditors and accountants, lawyers and notaries, and corporate service providers. Your sector supervisor sets out how the framework applies to your activity.
Core duties and how groAML supports them
| Duty | What it involves | In groAML |
|---|---|---|
| Customer due diligence | Identify and verify customers and beneficial owners, understand the relationship, and keep the information current. | Customer case file, ownership diagrams, UAE PASS verification, Emirates ID and passport scanning, periodic review tracking. |
| Sanctions screening | Screen customers and related parties against sanctions and terrorist lists and review potential matches. | Screening against UAE, UN, OFAC, EU and UK lists, PEP data, alert review with a second-reviewer workflow. |
| Suspicious transaction reporting | Report suspicious transactions and activity to the UAE Financial Intelligence Unit through goAML. | STR/SAR builder and goAML 5.0 XML export from the case file. |
| Record-keeping | Keep customer, transaction and report records so they can be produced when asked. | Append-only audit trail, stored documents and evidence packs, retention dates set per customer. |
| Targeted financial sanctions | Act on listed persons and entities, including freezing, and report what was done. | Freeze obligations created from confirmed matches and tracked until executed, with reminders to the MLRO. |
Instruments to read
Firms commonly work from these instruments. Check the current text and your supervisor's guidance for the requirements that apply to you.
- Federal Decree-Law No. 10 of 2025
- Cabinet Resolution No. 134 of 2025
- Cabinet Decision No. 109 of 2023
- Cabinet Resolution No. 74 of 2020
This page is general information, not legal advice.