AML Laws in the UAE: At a Glance
UAE AML/CFT compliance is no longer a box-ticking exercise. UAE AML/CFT compliance is now anchored in a strengthened legal framework under Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
It is a governance and risk discipline that requires clear accountability, risk-based controls, and reliable evidence. For regulated businesses, the key is to translate legal obligations into day-to-day operational controls that can withstand supervisory review. This guide by GRC Advisors sets out the applicable legal framework, practical obligations, and implementation priorities for DNFBPs, VASPs, and financial institutions.
Who this Guide Applies to
This guide is designed for:
- DNFBPs such as DPMS, real estate brokers, legal professionals, TCSPs, and commercial gaming operators, accounting and audit firms
- VASPs and other virtual asset businesses
- Financial institutions across banking, exchange, insurance, and securities activities
- Boards, senior management, MLROs, compliance teams, and operations leaders
If you need a practical legal map and a realistic implementation route, this is your starting point.
UAE AML Laws and Regulations Applicable Across Sectors
Under the UAE new AML law, the legal framework and the implementing framework should be read together:
Federal Decree Law No. 10 of 2025 establishes the core legal obligations and enforcement posture.
Cabinet Resolution No. 134 of 2025 provides implementation depth and practical compliance direction.
For AML/CFT teams, this means the focus should move beyond drafting and into control performance. Policies, procedures, systems, and governance forums should all align to the same compliance objective: risk based prevention, detection, escalation, and reporting.
Legal and Regulatory Basis
The UAE model is best understood as a layered compliance architecture:
- Federal law defines offences and high-level obligations
- Implementing regulation sets operational expectations
- Sanctions framework defines TFS duties and related controls
- Jurisdictional rulebooks and sectoral guidance provide regulator-specific detail
- Internal governance framework turns legal duties into verifiable controls
This approach helps avoid a common error in which firms maintain policy documents but cannot demonstrate control effectiveness.
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Establishing an Effective AML Framework in UAE
For most regulated entities in the UAE, an effective AML/CFT framework depends on five essentials:
- Risk-based governance and oversight
- Customer due diligence and enhanced due diligence
- Ongoing monitoring and sanctions screening
- Escalation and suspicious activity reporting
- Recordkeeping, training, and independent assurance
At GRC Advisors, we see the same pattern across sectors. Firms usually understand what must be done. The real challenge is proving that controls are properly designed, consistently applied, and regularly reviewed. Get in touch with us to avail GRC Services in UAE.
Core AML Obligations in UAE
For most regulated entities in the UAE, an effective AML/CFT framework depends on five essentials:
Across sectors, the obligations are consistent in principle and different in execution detail.
- Risk-based governance:
Senior management must set direction, assign accountability, and monitor implementation quality.
- CDD and EDD:
Entities must identify and verify customers, understand beneficial ownership where applicable, and apply enhanced scrutiny where risk is higher.
- Ongoing monitoring:
Monitoring should be proportionate to customer and transaction risk, with trigger based review capability.
- Screening controls:
Sanctions and related screening must be timely, documented, and supported by clear match handling standards.
- Escalation and reporting:
Internal escalation procedures should support timely, well-evidenced reporting when suspicion arises.
- Recordkeeping and assurance:
Documentation should be complete enough to reconstruct decisions, demonstrate control operations, and support independent testing.
Step-by-Step AML Compliance Framework
At GRC Advisors, we recommend the following sequence:
Step 1: Create a legal obligations register
Map each requirement to the source instrument, the business owner, and the control.
Step 2: Complete enterprise and customer risk assessments
Use actual exposure data by sector, product, geography, and channel.
Step 3: Convert policy into procedures
Define how each control operates in practice, including timelines and evidence standards.
Step 4: Implement control architecture
Deploy CDD, EDD, monitoring, screening, and escalation controls aligned to your risk profile.
Step 5: Build reporting and QA workflow
Set escalation thresholds, reviewer responsibilities, and quality review checks.
Step 6: Test and remediate
Run control testing, track findings, close actions, and retest.
Step 7: Report through management information
Use meaningful metrics such as alert ageing, review backlog, screening disposition quality, and training completion rates.
Sector Pathways
Use this parent guide as the overview layer, then move to the relevant sector hub:
- DNFBP pathway:
DPMS, real estate, legal, TCSP, accounting and audit
- VASP pathway:
Exchange, custody, brokerage, and transfer-related activities
- FI pathway:
Banks, exchange houses, insurers, securities businesses
- Jurisdiction pathway:
ADGM, DIFC, VARA, CMA contexts
Common Mistakes and Remediation Priorities
- Documentation without implementation
Policies exist, but controls are not consistently executed.
- Generic risk scoring
Risk methodology is not calibrated to actual customer and transaction patterns.
- Weak escalation narrative
Internal escalations are incomplete, inconsistent, or unsupported by evidence.
- Fragmented recordkeeping
Evidence trails cannot be easily produced for review.
- Non-targeted training
Training is broad and not tailored to role-specific decisions.
For most firms, remediation should prioritise control evidence quality and escalation governance first.
AML Legal Framework in UAE: Frequently Asked Questions
Is AML/CFT compliance in the UAE only relevant for banks?
No. It applies to a wider regulated population, including DNFBPs and VASPs, depending on activity.
Do free zone entities only follow local free zone rules?
No. Firms must consider federal AML/CFT requirements alongside the relevant jurisdiction specific rulebooks.
Is goAML only an administrative task?
No. Reporting quality depends on upstream controls, escalation discipline, and documentation standards.
Is annual policy review enough?
Usually not. High quality programmes use continuous monitoring, periodic recalibration, and documented remediation.
