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AML Compliance Servicesin Dubai and the UAE
Bestax helps Dubai businesses build and maintain a practical AML framework.
We review what applies to your activity, identify gaps, support goAML access and reporting, and prepare your business for Ministry of Economy and Tourism compliance checks.
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Tax AgencyNo. 30008692 - Business Setup Partner
for Dubai Free Zones - 10+YEARSof Experience
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Talk to an
AML Consultant
Tell us your licence activity, your regulator and where your customers and payments come from, and we will confirm what actually applies to you.
Recognition, Accreditations & Partnership
The approvals and registrations behind the work.
IFZA Gold Tier Partner Recognition
Gold Tier Recognition · Elite Loyalty Programme
Accounting Software Experience
Hands-on Experience Across Leading Accounting Platforms
ICAEW Approved Employer
Supporting Professional Training and Development
KIZAD
Business Setup Partner in Abu Dhabi
Meydan Free Zone
Company Formation Partner in Dubai
SHAMS — Sharjah Media City
Business Setup Partner in Sharjah
Sharjah Publishing City
Free Zone Company Formation Partner
Payoneer
Referral Partner for International Payments
The Approach
Bestax AML Consultants in Dubai
Good AML support should tell you what you actually need, not hand you a generic policy file.
We start by checking your licence activity, regulator, customer types, payment methods, countries involved and the level of money laundering, terrorism financing and proliferation financing risk in your business.
Our support can include:
- Business-wide AML, CFT and CPF risk assessment
- Compliance gap review against current UAE requirements
- goAML access and reporting support
- Compliance Officer or MLRO role review and documentation
- Customer Due Diligence and Enhanced Due Diligence procedures
- Beneficial owner and PEP checks
- Sanctions and Targeted Financial Sanctions screening procedures
- Suspicious Transaction Report and Suspicious Activity Report procedures
- AML policies, controls and customer risk-rating tools
- Staff training and practical red-flag guidance
- Record-keeping framework
- Mock inspection and remediation support
Who Is In Scope
Who Must Follow Anti Money Laundering UAE Requirements?
Under the current UAE framework, financial institutions, Virtual Asset Service Providers and Designated Non-Financial Businesses and Professions can have AML obligations. For DNFBPs supervised by the Ministry of Economy and Tourism, the main categories include the businesses below.
Real estate agents and brokers
Businesses involved in buying or selling real estate for customers
Dealers in precious metals and stones
Gold, jewellery, diamonds, precious metals and precious-stone businesses
Independent accountants and auditors
Accounting, audit and assurance professionals within the regulated scope
Trust and company service providers
Company formation, registered office and selected corporate administration services
DNFBPs in mainland UAE and commercial free zones can fall under Ministry supervision. Businesses in the DIFC and ADGM may instead be supervised by the DFSA or FSRA, so the regulator must be confirmed before applying a compliance checklist.
What Is At Stake
Why AML Compliance Matters for Dubai Businesses
Avoid preventable fines
Administrative penalties can apply for weak policies, missing risk assessments, poor CDD, failure to report suspicions, missing records and other compliance failures.
Prepare for inspection
The Ministry actively supervises DNFBPs and continued inspections remain part of the UAE compliance framework.
Protect banking relationships
Banks often ask businesses to explain ownership, source of funds, customers and transaction patterns. A weak compliance file can create avoidable questions.
Make staff decisions consistent
A clear risk-based process helps staff know when normal CDD is enough, when EDD is needed and when a matter should be escalated to the MLRO.
Protect your licence and reputation
AML failures can lead to more than a financial cost. Serious cases can involve further regulatory action and separate criminal consequences.
Keep up with changing risks
High-risk country lists, sanctions requirements and sector guidance are updated. Your AML programme should change when the risks change.
Reporting Access
AML Registration: goAML Setup and Reporting Access
For reporting entities, access to the UAE Financial Intelligence Unit’s goAML system is a core part of the reporting process. The Ministry currently states that registration is mandatory for DNFBPs and that the registration itself is free.
The process includes pre-registration through the protection system, use of Google Authenticator and registration of the organisation in goAML. Typical documents include the trade licence, an authorisation letter and identification documents for the authorised compliance person.
Our AML registration support focuses on getting the organisation details, compliance contact and supporting documents aligned before submission. Once access is approved, the system is used for the reports that apply to the business, including suspicious transaction or activity reporting.
- Mandatory for DNFBPs, and free to register
- Pre-registration through the protection system
- Google Authenticator, then the organisation in goAML
- Trade licence, authorisation letter and ID documents
- Suspicious transaction or activity reporting
The Framework
What Your AML Compliance Framework Should Cover
Business risk assessment
Document the risks linked to customers, countries, products, services, transaction channels and the way your business operates. The assessment must be reviewed and updated as risks change.
AML policies and internal controls
Policies should match the real size and risk of the business. A copied manual that staff do not use is not enough.
Customer Due Diligence
Identify and verify customers and beneficial owners, understand the purpose of the relationship and obtain enough information to assess risk.
Enhanced Due Diligence
Apply stronger checks where risk is higher, including appropriate source-of-funds or source-of-wealth work and closer monitoring.
PEP controls
Have a process to identify politically exposed persons and apply the additional controls required by the risk.
Ongoing monitoring
Review transactions and customer information so unusual activity, changed ownership or a changed risk profile is not missed.
Sanctions screening
Screen customers and relevant parties against applicable UAE and UN sanctions requirements and act promptly on confirmed or potential matches.
Suspicious reporting
Staff need a clear internal escalation process. The Compliance Officer or MLRO must be able to assess the concern and file the required report without inappropriate interference.
Staff training
Training should match the employee’s role and show real red flags for the company’s sector, not only definitions from the law.
Record keeping
Keep CDD, transaction, monitoring, risk-assessment and reporting records in a form that can be provided to the authorities without undue delay.
The Current Law
AML Compliance Dubai: What Changed for 2026?
The UAE’s current principal AML law is Federal Decree-Law No. 10 of 2025, supported by Cabinet Resolution No. 134 of 2025. The new executive framework became effective in December 2025 and the Ministry issued updated DNFBP guidance in March 2026.
For AML compliance Dubai businesses should now make sure their programme also addresses proliferation financing risk, current high-risk country measures, senior-management responsibility and the effectiveness of the Compliance Officer role. The Ministry’s 2026 DNFBP guidance also stresses practical risk assessment, CDD, ongoing monitoring, suspicious reporting, training and record keeping.
- Federal Decree-Law No. 10 of 2025The UAE’s current principal AML law.
- Cabinet Resolution No. 134 of 2025The executive framework, effective December 2025.
- Ministry DNFBP guidanceUpdated guidance issued in March 2026.
Compliance Officer and MLRO Responsibilities
DNFBPs are required to appoint a qualified Compliance Officer. Current Ministry guidance says the role should sit at management level, have appropriate authority and independence, and have access to the information needed to perform the job.
The Compliance Officer, also commonly called the MLRO for reporting responsibilities, should oversee the risk assessment, policies, CDD, monitoring, sanctions screening, training, records and reporting process. Senior management remains accountable for compliance even when a permitted third-party compliance arrangement is used.
Customer Due Diligence, KYC and Beneficial Ownership
KYC is only one part of CDD. A compliant process should identify the customer, verify identity from reliable sources, identify and verify the beneficial owner where required, understand why the customer is using your service and assign a risk level.
Higher-risk relationships need stronger checks. That can include more information about the ownership chain, source of funds, source of wealth, expected transactions, countries involved and the reason for unusual payment methods.
Ownership records used for AML should also stay consistent with your UBO compliance records. Keeping the two processes aligned reduces avoidable gaps when regulators or banks review the company.
Suspicious Transaction and Activity Reporting
A business should not wait for proof of a crime before escalating a genuine suspicion. DNFBPs must have procedures to identify unusual activity, assess the concern and report to the UAE Financial Intelligence Unit when the legal reporting test is met.
The report and the fact that a report may be filed must remain confidential. Telling the customer or another unauthorised person about a suspicious report or related investigation can create separate legal exposure.
Record Keeping for AML Inspections
The Ministry’s March 2026 DNFBP guidance states that the minimum statutory retention period for relevant CDD and transaction records is five years, calculated from the latest applicable event listed in the guidance. Authorities can require a longer period in specific cases.
Your files should allow a reviewer to understand who the customer was, what checks were completed, why the risk rating was chosen, what transactions were reviewed, what concerns were escalated and what action was taken.
Strong bookkeeping also makes transaction review easier. If your financial records are incomplete, consider linking this work with Accounting and Bookkeeping Services in Dubai.
5 yearsMinimum statutory retention for CDD and transaction records
AML Fines UAE Penalty Guide for Common DNFBP Failures
The current administrative penalty schedule used for DNFBPs under Ministry of Justice and Ministry of Economy and Tourism supervision is Cabinet Resolution No. 71 of 2024. The resolution remains listed as active and replaced the older Cabinet Resolution No. 16 of 2021.
| Example Compliance Failure | Published Administrative Fine Range |
|---|---|
| No top-management-approved AML policies and controls | AED 100,000 to AED 200,000 |
| Failure to identify, assess and update business AML risks | AED 50,000 to AED 500,000 |
| Failure to carry out required customer due diligence | AED 50,000 to AED 200,000 |
| Failure to apply Enhanced Due Diligence for identified high risk | AED 100,000 to AED 500,000 |
| Failure to promptly report suspicious transactions to the FIU | AED 100,000 to AED 500,000 |
| Failure to register on the FIU-approved electronic reporting system | AED 50,000 to AED 200,000 |
| Failure to appoint a suitably competent compliance officer | AED 50,000 to AED 200,000 |
| Failure to keep required AML records and data | AED 50,000 to AED 200,000 |
| Failure to register for applicable sanctions-list notifications | AED 50,000 to AED 1,000,000 |
| Dealing with shell banks | AED 200,000 to AED 1,000,000 |
This AML fines UAE penalty table is a practical summary, not a substitute for reviewing the exact violation and regulator. The same resolution allows the Ministry to double the administrative fine for a repeated violation, and other administrative measures may also apply.
AML Penalties UAE Businesses Should Not Ignore
AML penalties UAE businesses face are not limited to one fixed fine. The amount depends on the breach, and repeated administrative violations can be treated more severely.
The 2025 federal AML law also contains separate criminal offences and penalties for matters such as money laundering, terrorism financing, tipping off and certain intentional or grossly negligent compliance failures. That is why a business should fix a compliance gap when it is found rather than wait for an inspection.
AML Risk Assessment and Compliance Review
A risk assessment is the starting point for a useful AML programme. Bestax reviews your customers, services, payment methods, transaction values, delivery channels, geographic exposure, ownership risks and any sector-specific red flags.
We then compare your existing controls with the current UAE requirements and create a clear remediation list. This helps management see what is missing, what needs updating and which gaps create the highest regulatory risk.
AML Policies and Procedures Built for Your Business
Your policy should reflect how your company actually works. We can help structure customer acceptance rules, CDD and EDD steps, PEP handling, source-of-funds checks, sanctions screening, transaction monitoring, internal escalation, suspicious reporting, training and record keeping.
The aim is to create a process employees can follow and management can evidence during an inspection.
AML Training for Staff and Management
Staff who speak to customers, review documents, handle payments or approve transactions need to understand the red flags relevant to their role. Training should explain what to look for, when to stop and ask for more information, and when to escalate the matter to the Compliance Officer.
Management training is also important because senior management approves the framework, provides resources and remains responsible for making sure the compliance programme works.
AML Inspection Readiness and Remediation
A regulator may ask for more than a policy document. Your business should be able to show risk assessments, customer files, beneficial-owner checks, risk ratings, screening evidence, training records, MLRO reports, monitoring results and proof that identified gaps were fixed.
Bestax can review a sample of your files, test whether the policy is being followed and create an action plan before a supervisory inspection.
Where broader internal-control weaknesses are found, the review can be coordinated with Internal Audit Services in Dubai so the remediation covers both AML and wider control issues.
Our AML Compliance Process
Scope check
Confirm your activity, licensing authority and whether the DNFBP rules apply to your business.
Gap assessment
Review existing registration, policies, risk assessment, CDD files, MLRO arrangements and reporting procedures.
Risk assessment
Document the risks specific to your business and customer base.
Remediation plan
Prioritise missing or weak controls based on regulatory risk.
Implementation
Prepare or update policies, forms, risk ratings, screening steps and reporting processes.
Staff training
Train relevant employees using practical examples and escalation steps.
Inspection readiness
Test selected files and evidence before a regulator requests them.
Ongoing review
Update the framework when the business, customer risk, sanctions environment or regulatory guidance changes.
Why Bestax
Why Choose Bestax for AML Support?
- Dubai-based accounting and compliance team
- 10+ years of UAE practice
- Support that connects AML with accounting, audit, tax and company records
- Practical policies and controls built around your actual business
- Clear explanation of what is mandatory and what is only good practice
- Inspection-readiness and remediation support
- One team for ongoing records, UBO and wider compliance work
Our Strength in Numbers
10+Years
UAE accounting and compliance experience
35+Professionals
Accounting, audit, tax and compliance team
1,000+Clients
Businesses supported across the UAE and beyond
Frequently Asked Questions
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