AML/CFT for designated non-financial businesses
AML compliance and goAML for DNFBPs in the UAE
The UAE has a new anti-money laundering law. Federal Decree-Law 10 of 2025 took effect on 14 October 2025 and replaced Federal Decree-Law 20 of 2018. Its executive regulation, Cabinet Resolution 134 of 2025, took effect on 14 December 2025. Designated non-financial businesses and professions (DNFBPs), such as real estate agents, dealers in precious metals and stones, corporate service providers, and accountants and auditors, must register on goAML and report suspicious transactions there.
With UAE Accountant you send one free request describing your business and where you stand. Up to three firms that provide AML compliance support contact you with quotes. We are a matching service and do not give legal advice.
What AML compliance support covers
Firms help you build and run a programme that fits the new law. Common parts:
goAML registration
Registering your business on goAML, the platform where DNFBPs file suspicious transaction reports.
Business risk assessment
Assessing the money-laundering and terrorist-financing risks of your clients, products, payment methods and locations.
Policies and procedures
Written AML/CFT policies, customer due diligence steps and record-keeping rules, updated for Federal Decree-Law 10 of 2025.
Customer due diligence set-up
Checklists and forms for identifying clients and their beneficial owners, and for higher-risk clients.
Training
Training staff to spot red flags and know how and when to escalate a suspicion.
Reviews and health checks
Independent checks of how your programme works in practice, before a supervisor visits.
Who is a DNFBP?
DNFBPs are businesses outside banking that the law treats as exposed to money laundering. Examples:
- Real estate agents and brokers
Businesses that act in property sales and purchases.
- Dealers in precious metals and stones
Gold, jewellery and gemstone traders, on the mainland and in free zones.
- Corporate service providers
Businesses that form and manage companies for their clients.
- Accountants and auditors
Accounting and audit firms themselves. Under Federal Decree-Law 41 of 2023, audit firms must also have AML procedures.
Your supervisor depends on where you are licensed. The Ministry of Economy and Tourism supervises DNFBPs on the mainland and in commercial free zones. The DFSA supervises firms in DIFC, and the Registration Authority supervises firms in ADGM.
Key dates and timing
AML compliance is ongoing, not a once-a-year filing. The dates and timing that matter:
| What | Date or timing |
|---|---|
| Federal Decree-Law 10 of 2025 in force | 14 Oct 2025 |
| Executive regulation (Cabinet Resolution 134 of 2025) in force | 14 Dec 2025 |
| goAML registration | Required for DNFBPs. Do it before you need to file a report |
| Suspicious transaction reports | Filed on goAML when a suspicion arises |
| Policies and risk assessment | Review them now if they were written under the old 2018 law |
Supervisors can inspect DNFBPs and impose penalties for gaps. The exact sanctions and timings are set by the law and its regulation. Ask a compliance firm what applies to your business.
What to prepare
- Your trade licence and its activities, and the licensing authority (mainland or free zone).
- Your ownership structure and beneficial owner register.
- A description of your clients, services, payment methods and typical transaction sizes.
- Any existing AML policy, risk assessment or goAML login.
- The name of your compliance officer, if you have one.
- Any letters or inspection findings from your supervisor.
Companies must keep a beneficial owner register under Cabinet Decision 109 of 2023. Your AML programme will draw on it.
What affects the fee
AML support is priced by scope. The main factors:
Your sector and risk
Gold, real estate and corporate services usually need more detailed controls.
Starting point
Building a programme from nothing is more work than updating one for the 2025 law.
Size and branches
More staff, branches and clients mean more training and procedures.
Ongoing support
One-off set-up versus ongoing compliance officer support or periodic reviews.
Supervisor deadlines
An inspection or a finding to close quickly adds urgency.
What to ask a firm before you choose
Ask each firm:
- What trade licence do you hold, and does it include compliance or consultancy activities?
- Have you updated your templates for Federal Decree-Law 10 of 2025 and Cabinet Resolution 134 of 2025?
- Do you know the expectations of my supervisor (MoET, DFSA or the ADGM Registration Authority)?
- Who will train my staff, and how often?
- What stays with us, and what do you do for us each year?
Mistakes to avoid: relying on a policy written for the old 2018 law, buying a template that does not match your business, and assuming registration on goAML is the whole job. We ask each partner firm for its trade licence and its activities.
How to get AML compliance quotes
- 1
Send one request
Choose AML compliance, and tell us your sector, emirate or free zone and where you stand today. It is free.
- 2
Firms contact you
Up to three firms ask about your business and risks and send a quote.
- 3
Compare and choose
Compare scope, sector experience and ongoing support, then choose one firm.
Available in these emirates
AML compliance: common questions
Which AML law applies in the UAE now?
Federal Decree-Law 10 of 2025, in force since 14 October 2025. It replaced Federal Decree-Law 20 of 2018. Its executive regulation took effect on 14 December 2025.
What is goAML?
goAML is the platform where DNFBPs register and file suspicious transaction reports.
Am I a DNFBP?
Examples include real estate agents, dealers in precious metals and stones, corporate service providers, and accountants and auditors. A compliance firm can confirm whether your activities are covered.
Who supervises my business?
The Ministry of Economy and Tourism for mainland and commercial free zones, the DFSA in DIFC, and the Registration Authority in ADGM.
Is AML the same as economic substance reporting?
No. Economic substance reporting ended for financial years ending after 31 December 2022. AML compliance is a separate, ongoing duty.
Can my accounting firm handle AML too?
Some can. Mention it in your request together with bookkeeping or audit and firms can quote for both.
Related services
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