Gap assessment
Confirm your DNFBP category and supervisor, review what you have, and give you a prioritised list of gaps.
AML Compliance Services in Dubai and the UAE: goAML, Risk Assessments, Policies and Independent AML Audits
AML compliance services help UAE businesses that are designated non-financial businesses and professions (DNFBPs), such as real estate brokers, precious metals dealers, accountants and company service providers, meet Federal Decree-Law No. 10 of 2025. SGA World handles goAML, risk assessments, policies, sanctions screening, training and independent AML audits.
- Ministry of Economy and Tourism approved auditor
- 500+ clients
- Dubai & Abu Dhabi
AML compliance at a glance
- Law
- Federal Decree-Law No. 10 of 2025
- Regulations
- Cabinet Resolution No. 134 of 2025
- DNFBP supervisor
- Ministry of Economy and Tourism
- Reporting
- goAML, UAE Financial Intelligence Unit
- Sanctions
- EOCN targeted financial sanctions
AML compliance services help a business prove, not just claim, that it can stop its services being used for money laundering, terrorist financing or proliferation financing. In the UAE, that obligation falls on banks and on designated non-financial businesses and professions (DNFBPs): real estate brokers, dealers in precious metals and stones, auditors and accountants, and company service providers.
The framework changed in 2025. Federal Decree-Law No. 10 of 2025 replaced the 2018 AML law from 14 October 2025, and its executive regulations, Cabinet Resolution No. 134 of 2025, apply from 14 December 2025. Supervisors now expect DNFBPs to show a working programme: a documented risk assessment, customer files that match the policy, sanctions screening that is actually done, and reports filed on goAML when needed.
SGA World provides AML compliance services in Dubai and across the UAE, from first-time goAML registration to full programme design and independent AML audits. For the background on the law itself, read our AML compliance guide.
- Federal Decree-Law No. 10 of 2025 in force
- 2025 law
- Registration and reporting to the UAE FIU
- goAML
- Sanctions screening and freezing
- EOCN
- Independent testing of your programme
- Audit
At a glance
AML Compliance Services: Key Points
- Who: DNFBPs in four main sectors, supervised for mainland and commercial free zone businesses by the Ministry of Economy and Tourism (MoET).
- New law: policies that still cite Federal Decree-Law No. 20 of 2018 or Cabinet Decision No. 10 of 2019 need a real review, not a new cover page.
- Risk first: a written business-wide risk assessment drives every other control.
- Customers: CDD for every customer, EDD for higher-risk ones, and beneficial owners identified.
- Sanctions: screening against the UAE Local Terrorist List and UN lists, with freezing without delay on a match.
- Evidence: inspectors test files and decisions; a policy on its own is not compliance.
Our services
What Do Our AML Compliance Services Include?
Business risk assessment
Document risks from customers, owners, products, countries, channels and transactions, and the controls that reduce them.
Policies and procedures
AML, CFT and CPF policies and practical procedures written for your size and sector.
CDD, EDD and UBO
Onboarding forms, risk scoring, beneficial ownership checks and enhanced due diligence steps.
Sanctions screening
EOCN registration, screening against UAE and UN lists, match handling and freezing procedures.
goAML set-up
Registration, user roles and an internal route from staff concern to compliance officer decision.
Training
Role-based training with records that show who was trained, on what and when.
Independent AML audit
Testing files, screening, reports and governance, with findings and an action plan.
Ongoing support
Periodic file reviews, policy updates and inspection readiness checks.
Who needs it
Which UAE Businesses Need AML Compliance Services?
Real estate brokers and agents
When involved in transactions for clients buying or selling property. Cash and virtual asset payments trigger extra reporting.
Dealers in precious metals and stones
Gold, jewellery and gemstone traders, including retail. Cash transactions at or above AED 55,000 must be reported.
Auditors and accountants
Independent accountants carrying out covered work for clients. The Ministry issued sector guidance for accountants and auditors in 2026.
Trust and company service providers
Company formation, registered office, nominee and administration services, where the risk lies in who really owns and controls a structure.
How it works
How Do We Build an AML Compliance Programme?
Step01
Confirm scope
Licensed activities, DNFBP category, supervisor and existing documents.
Step02
Assess risk
Map customers, beneficial owners, products, countries, channels and transactions, then rate inherent and residual risk.
Step03
Design controls
CDD and EDD rules, approval levels, screening, monitoring triggers, escalation and record keeping.
Step04
Register and train
goAML and EOCN registrations, compliance officer role and staff training.
Step05
Test and evidence
Sample real files and decisions, record gaps and remediation, and report to management.
Why SGA World
Why Choose SGA World for AML Compliance Services?
Auditors who test controls for a living
Our AML reviews are run by auditors, so we test real files and decisions, not just documents.
Ministry-approved audit firm
SGA World is a Ministry of Economy and Tourism approved audit firm, so our reports are accepted where it matters.
Audit and tax in one team
Auditors, VAT, corporate tax and transfer pricing specialists work together, so nothing falls between advisers.
Qualified chartered accountants
A team of chartered accountants qualified in India and the UK, focused on UAE rules.
500+ clients
Mainland and free zone companies, from start-ups and SMEs to regional groups.
Listed with major UAE banks
Our audit work is recognised by major UAE banks for facilities and account reviews.
What changed
What Changed in UAE AML Law in 2025?
| Point | Before | Now |
|---|---|---|
| Main law | Federal Decree-Law No. 20 of 2018 | Federal Decree-Law No. 10 of 2025, in force from 14 October 2025 |
| Executive regulations | Cabinet Decision No. 10 of 2019 | Cabinet Resolution No. 134 of 2025, from 14 December 2025 |
| Scope of offences | Money laundering and terrorist financing | Money laundering, terrorist financing and proliferation financing |
| Name of the ministry | Ministry of Economy | Ministry of Economy and Tourism |
| What it means for you | Policies written to the old texts | Risk assessment, policies and training should be reviewed against the new law |
Updating references alone is not enough. Supervisors expect the risk assessment, controls and evidence to reflect the current requirements.
goAML
Which Reports Do DNFBPs File on goAML?
- STR: suspicious transaction report
- When there are reasonable grounds to suspect a transaction or attempted transaction is linked to a crime, whatever the amount.
- SAR: suspicious activity report
- When suspicion relates to activity or behaviour rather than a specific transaction.
- DPMSR: dealers in precious metals and stones report
- For cash transactions at or above the threshold set for dealers (AED 55,000 under current guidance).
- REAR: real estate activity report
- For property transactions involving cash above the set threshold or payments in, or converted from, virtual assets.
- FFR: funds freeze report
- When screening confirms a match with a sanctions list and funds are frozen.
- PNMR: partial name match report
- When a screening hit cannot be ruled out and the transaction is suspended pending checks.
goAML registration gives you the reporting route; it does not prove the rest of the programme works.
Sanctions
How Should a DNFBP Handle Sanctions Screening?
Targeted financial sanctions in the UAE are coordinated by the Executive Office for Control and Non-Proliferation (EOCN). A compliant screening process means:
- registering for EOCN notifications so list updates arrive automatically;
- screening customers, beneficial owners and counterparties against the UAE Local Terrorist List and UN Security Council lists, at onboarding and when lists change;
- for a confirmed match: freezing funds and assets without delay, without prior notice, and reporting through goAML with an FFR;
- for a partial match that cannot be cleared: suspending the transaction and filing a PNMR;
- recording how every alert was resolved and who made the decision.
Sanctions screening and PEP screening are different checks; both should be built into onboarding.
Worked example
Example: A Property Buyer Paying Through a Third Party
A Dubai brokerage is instructed by a buyer purchasing an apartment through a company registered overseas. The deposit arrives from a different company in a third country, and the buyer is vague about who owns the purchasing company.
A working AML programme would lead the broker to:
1. Identify and verify the purchasing company and trace its ownership to the beneficial owners. 2. Ask why a third party is paying and obtain evidence of the source of funds. 3. Screen the buyer, the beneficial owners and the paying company against sanctions and PEP lists. 4. Apply enhanced due diligence and obtain senior approval before proceeding. 5. If the explanations do not remove the concern, the compliance officer considers filing an STR on goAML, without tipping off the customer. 6. Record each step and the reason for the final decision.
One red flag is not proof of a crime. What supervisors look for is that it was noticed, investigated and decided, with evidence.
What to prepare
What Should You Prepare for an AML Review?
Business and governance
Trade licence and activities, organisation chart, compliance officer appointment, management reports on AML.
Programme documents
Current risk assessment, AML policy and procedures, onboarding forms and risk-rating method.
Customer evidence
A sample of customer files with ID, beneficial ownership, risk ratings and EDD records.
Screening and reporting
Screening logs and match decisions, internal escalations, goAML status and reports filed.
Training records
Training plan, materials and attendance records.
Regulator contact
Previous inspection reports, circulars received and correspondence with the supervisor.
Fees and timing
How Much Do AML Compliance Services Cost in Dubai?
Fees depend on the work, not a fixed package. The main factors are:
- your sector and DNFBP category;
- the number of entities, branches and staff;
- the volume and complexity of customers and transactions;
- the state of your existing documents and files;
- whether you need a one-off review, a full programme build or ongoing support;
- urgency, for example a pending inspection.
After a short scoping call, we confirm a fixed fee and timetable in writing.
Avoid problems
Common AML Compliance Mistakes
Policy still based on the 2018 law
Out of date with Federal Decree-Law No. 10 of 2025
A template risk assessment
Does not reflect your real customers and risks
goAML registered but never used
Registration is not a working programme
No record of how screening alerts were cleared
Cannot prove sanctions compliance
Beneficial owners not identified
A core CDD failure
No independent testing
Gaps found by the inspector instead of by you
AML desk
Get an AML Programme You Can Explain and Evidence
Tell us your licensed activity, sector and what you already have. We will confirm the scope and a fixed fee before we start.
We handle
- Gap assessment
- Business risk assessment
- Policies, CDD and EDD
- goAML and EOCN set-up
- Training and independent AML audit
Location: Dubai & Abu Dhabi
Talk to Our Team
Our offices in Business Bay, Dubai and Al Bateen, Abu Dhabi support clients across the UAE.
Dubai
Office 1923, The Exchange Tower, Business Bay, Dubai
Abu Dhabi
Khalidiya Towers M-B6, W10, Al Bateen, Al Khalidiyah, Abu Dhabi
Talk to an auditor
Tell us your company type, jurisdiction and deadline. We will confirm the scope, timeline and fee.
- WhatsApp us+971 50 627 3556
- Call us+971 4 570 1795
- Email us[email protected]
- Book an appointmentChoose a time that suits you
Prefer a form? Send us a detailed enquiry.
Who prepared this page
Written and reviewed by SGA World's audit and tax team
This guide is prepared by chartered accountants at SGA World Auditing Accounting L.L.C S.P.C in Business Bay, Dubai, a Ministry of Economy and Tourism approved audit firm, and checked against Federal Tax Authority legislation and guidance. It is reviewed whenever the rules change.
- Last reviewed 14 October 2026
- Chartered accountants from India and the UK
- FTA representation through Saif Chartered Accountants
Have a question about your company?
Tell us your activity, jurisdiction and deadline. A chartered accountant will reply.
Ask an expertFrequently asked questions
AML Compliance Services – FAQs
Short answers to the questions UAE businesses ask us most. Still unsure?
Talk to our team01.What are AML compliance services?
Support that helps a business meet its anti-money laundering obligations: confirming scope, assessing risk, writing policies and procedures, setting up customer due diligence, sanctions screening and goAML reporting, training staff and testing that the programme works.
02.Which businesses are DNFBPs in the UAE?
The Ministry of Economy and Tourism lists real estate firms, auditing and accounting firms, dealers in precious metals and stones, and trust and company service providers. Lawyers and notaries are also covered, with the Ministry of Justice as supervisor.
03.Which AML law applies in the UAE now?
Federal Decree-Law No. 10 of 2025, in force from 14 October 2025, with executive regulations in Cabinet Resolution No. 134 of 2025, applying from 14 December 2025. They replaced Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019.
04.Do all UAE companies need a goAML account?
No. Financial institutions and DNFBPs must register on goAML. Other companies do not register, although banks will still ask them for KYC and beneficial ownership information.
05.Is an AML policy template enough?
No. A policy must reflect your actual risks, customers and processes, and inspectors test whether it is applied in customer files and decisions.
06.What is the difference between KYC, CDD and EDD?
KYC is the general process of knowing your customer. CDD is the required set of identification, verification and risk checks. EDD is the extra scrutiny applied to higher-risk customers, such as PEPs or complex structures.
07.Do we need to identify the ultimate beneficial owner of customers?
Yes. For corporate customers you must identify the natural persons who ultimately own or control them. See our UBO compliance service for how ownership chains are traced.
08.What does a business risk assessment cover?
Risks from customers, beneficial owners, products and services, countries, delivery channels and transaction types, the controls in place and the remaining risk, with an action plan.
09.When must a DNFBP file an STR?
When there are reasonable grounds to suspect that funds or a transaction, including an attempted transaction, are linked to a crime, whatever the amount. Proof is not required.
10.What is tipping off?
Telling a customer or third party that a report has been or may be filed. It is prohibited, so staff must escalate concerns internally and confidentially.
11.Are sanctions screening and PEP screening the same?
No. Sanctions screening checks for listed persons whose funds must be frozen; PEP screening identifies politically exposed persons who need enhanced due diligence. Both are required.
12.What does the compliance officer do?
Owns the AML programme day to day, reviews escalations, decides on and files reports, liaises with the supervisor and reports to senior management.
13.How often should AML controls be reviewed?
At least annually, and whenever the business, its customers, the law or guidance changes. Independent testing should be carried out regularly.
14.Can an adviser file suspicious transaction reports for us?
Reporting decisions belong to your appointed compliance function. An adviser can support the analysis and the process, but your business remains responsible for its reports.
15.How much do AML compliance services cost in Dubai?
It depends on your sector, size, existing documents and the scope of work. We confirm a fixed fee after a short scoping call.
16.Who supervises AML compliance for DNFBPs in the UAE?
The Ministry of Economy and Tourism supervises DNFBPs on the mainland and in commercial free zones. Lawyers and notaries fall under the Ministry of Justice, DIFC firms under the DFSA, ADGM firms under the FSRA, and banks and insurers under the Central Bank.
17.What are common AML red flags for real estate and gold dealers?
Unexplained source of funds, third-party payments, large cash or crypto payments, transactions split to stay under thresholds, complex ownership without a business reason, and reluctance to provide documents.
18.What will an AML inspection ask to see?
The business risk assessment, current policies, the compliance officer appointment, a sample of customer files, sanctions screening evidence, goAML registration and reports, training records and independent testing results.
