AML Compliance in the UAE: A Practical Guide for Businesses in Dubai, Abu Dhabi and Free Zones (2026)

Anti-money laundering (AML) rules in the UAE apply far beyond banks. Real estate brokers, gold and jewellery dealers, company service providers, and auditors and accountants in certain work all have legal duties to know their customers, assess risk and report suspicious activity. Since 14 October 2025, these duties sit under a new federal AML law.

This guide explains the current framework, which businesses are covered, what an AML programme includes, how goAML reporting works and the red flags to watch for.

What Is the UAE’s AML Law in 2026?

Law	What it does
Federal Decree-Law No. 10 of 2025	The main AML, counter-terrorist financing and counter-proliferation financing law, in force from 14 October 2025. It replaced Federal Decree-Law No. 20 of 2018
Cabinet Resolution No. 134 of 2025	The executive regulations setting out how the duties are carried out in practice
Cabinet Decision No. 109 of 2023	Rules on beneficial ownership (UBO) records for companies

The new law keeps the core of the previous regime, including suspicious transaction reporting to the Financial Intelligence Unit (FIU), and adds:

• a standalone framework for proliferation financing;
• tax evasion as a predicate offence for money laundering;
• express coverage of virtual assets.

Which UAE Businesses Need AML Compliance?

Banks, exchange houses and insurers are supervised by financial regulators. Outside the financial sector, the main group is Designated Non-Financial Businesses and Professions (DNFBPs), supervised for mainland and commercial free zone businesses by the Ministry of Economy and Tourism:

Business	When AML duties apply
Real estate brokers and agents	When carrying out property transactions for clients
Dealers in precious metals and stones	Gold, diamonds and jewellery, especially in cash transactions
Company and trust service providers	Forming companies, acting as nominees or providing registered addresses
Auditors and accountants	When preparing for or carrying out certain transactions for clients, such as buying property, managing client funds or forming companies
Lawyers and notaries	When acting for clients in specified transactions

Other businesses, such as general trading companies with complex cross-border payments, may not be DNFBPs but are still expected by banks to show strong know-your-customer (KYC) controls.

What Does a UAE AML Programme Include?

Element	What it involves
Risk assessment	A documented assessment of your customers, products, countries and channels
Policies and procedures	Written AML policies approved by management
Compliance officer	An appointed AML compliance officer, registered on goAML
Customer due diligence (CDD)	Identifying and verifying customers before doing business
Beneficial owners (UBO)	Identifying the natural persons who ultimately own or control a customer
Enhanced due diligence	Extra checks for high-risk customers, including politically exposed persons
Sanctions screening	Checking customers against UAE and UN sanctions lists
Ongoing monitoring	Reviewing transactions against the customer’s expected profile
Reporting	Filing suspicious transaction and activity reports, and required threshold reports, on goAML
Record keeping	Keeping CDD and transaction records for the required period
Training and independent review	Regular staff training and periodic testing of the programme

What Is goAML and Who Must Register?

goAML is the reporting platform of the UAE Financial Intelligence Unit. DNFBPs must register on goAML and use it to file reports, including:

• suspicious transaction reports (STRs) and suspicious activity reports (SARs);
• real estate activity reports for property transactions paid in cash, or with virtual assets, at or above AED 55,000;
• dealers in precious metals and stones reports for cash transactions of AED 55,000 or more, including linked transactions.

The Ministry of Economy and Tourism has suspended DNFBPs that failed to register on goAML, so registration is not optional.

Expert tip: register on goAML before your first reportable transaction, not after. A late registration is itself a violation, and you cannot file a report on time without access.

How Is AML Different in Dubai, Abu Dhabi and the Free Zones?

The federal AML law applies across the UAE. What differs is the supervisor:

• Mainland and commercial free zone DNFBPs in Dubai, Abu Dhabi and other emirates are supervised by the Ministry of Economy and Tourism.
• Financial free zones have their own regulators: the DFSA in the DIFC and the FSRA in ADGM.
• Banks and financial institutions are supervised by the Central Bank of the UAE.

What Are Common AML Red Flags?

Customer and ownership:

• reluctance to identify beneficial owners, or frequent changes in ownership;
• complex structures with no clear business reason;
• customers linked to high-risk or sanctioned countries.

Transactions:

• large cash payments, or payments split to stay below AED 55,000;
• payments from unrelated third parties;
• prices well above or below market value;
• quick resale of property or assets with no clear reason.

Documents:

• inconsistent or altered documents;
• addresses that are virtual offices with no activity;
• unwillingness to explain the source of funds.

How Do AML and UBO Rules Connect?

UAE companies must keep a register of beneficial owners and file UBO details with their licensing authority. AML due diligence relies on the same information. Keeping your own UBO records current, and checking your customers’ UBOs, helps with both bank onboarding and AML compliance.

AML Compliance Checklist for UAE Businesses

• Confirm whether your business is a DNFBP for any of its activities.
• Register on goAML and appoint a compliance officer.
• Prepare and approve a written risk assessment and AML policy.
• Set up CDD, UBO and sanctions screening procedures.
• Define what triggers enhanced due diligence.
• Train staff and keep training records.
• Monitor transactions and file STRs, SARs and threshold reports on time.
• Keep records for the required period.
• Arrange a periodic independent review of the programme.

How SGA World Supports AML Compliance

SGA World helps UAE businesses assess whether AML rules apply, prepare risk assessments and AML policies, set up CDD and UBO procedures, and review existing AML programmes through our AML compliance services, including goAML registration and independent AML audits, and as part of our compliance auditing services.