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AML/CFT · Banks and DNFBPs

AML compliance in the UAE

AML compliance in the UAE rests on Federal Decree-Law No. 10 of 2025 on anti-money laundering, combating the financing of terrorism and proliferation financing, and on Cabinet Resolution No. 134 of 2025, its executive regulations. Banks, other financial institutions and DNFBPs have to assess their risks, know their customers, apply targeted financial sanctions, report suspicions and keep records. Sanctions screening is the part OFACScreen does.

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The UAE AML law and regulations

The AML/CFT law

Federal Decree-Law No. 10 of 2025, issued on 30 September 2025, repealed Federal Decree-Law No. 20 of 2018. It covers money laundering, the financing of terrorism and proliferation financing, and it counts the evasion of direct and indirect taxes among the predicate offences.

The executive regulations

Cabinet Resolution No. 134 of 2025 sets out how the law applies: which businesses count as DNFBPs, when customer due diligence is due, what the compliance officer does and how long records are kept.

Targeted financial sanctions

Cabinet Decision No. 74 of 2020 governs the UAE Local Terrorist List and the application of UN Security Council sanctions. The Executive Office for Control and Non-Proliferation (EOCN) publishes the lists and the guidance, and the law requires reporting entities to implement its instructions forthwith.

The supervisors

Each sector answers to a supervisory authority. The Ministry of Economy and Tourism supervises real estate brokers, dealers in precious metals and stones, auditors and accountants, and company service providers on the mainland and in the commercial free zones. The Ministry of Justice supervises lawyers and other legal professionals. Banks and the other institutions the Central Bank of the UAE licenses answer to the Central Bank.

What the law asks of a reporting entity

  1. 1

    Assess your risk and write it down

    Identify, assess and document the money laundering, terrorist financing and proliferation financing risks in your business, keep the assessment up to date and hand it to your supervisor on request.

  2. 2

    Appoint a compliance officer

    At management level, independent in decision-making and with the competence and experience for the job. The compliance officer reviews suspicious transactions and decides what goes to the Financial Intelligence Unit.

  3. 3

    Know your customers

    Customer due diligence and ongoing monitoring at the start of every business relationship, whenever there is a suspicion of a crime and whenever you doubt the customer data you hold. Financial institutions also apply it to occasional transactions of AED 55,000 or more.

  4. 4

    Apply targeted financial sanctions

    Subscribe to the EOCN's notifications, screen customers, their beneficial owners and the parties to a transaction against the UAE Local Terrorist List and the UN Security Council list, and freeze without delay on a match. See EOCN and TFS screening.

  5. 5

    Report through goAML

    Suspicious transaction reports go to the Financial Intelligence Unit through goAML, whatever the amount. Sanctions name matches go to the EOCN through the same platform. See goAML registration.

  6. 6

    Keep records

    Transaction records and customer due diligence files are kept for not less than five years from the completion of the transaction or the end of the business relationship, and handed to the authorities promptly on request.

AML in Dubai and the free zones

The Decree-Law is federal, so AML compliance in Dubai follows the same law as in Abu Dhabi or Sharjah. What changes is the supervisor. The Ministry of Economy and Tourism's supervision of DNFBPs covers the mainland and the commercial free zones. In the DIFC the Dubai Financial Services Authority supervises firms for AML/CFT compliance, and in the ADGM its Financial Services Regulatory Authority does.

Breaking the law has two kinds of consequence. A supervisor can impose administrative penalties, from a warning to fines of AED 10,000 to AED 5,000,000 per violation. Violating the EOCN's targeted financial sanctions instructions is a crime punishable by imprisonment and a fine of not less than AED 20,000, or either.

What OFACScreen covers, and what it does not

OFACScreen screens names against sanctions lists. In an account, the UAE Local Terrorist List is an optional list you add to a search, a CSV batch, an API call or your monitored names, next to the UN list and the others searched by default. Plans keep an audit trail of every search and re-screen saved names every day.

Customer due diligence, PEP and adverse media checks, transaction monitoring and goAML reporting are not part of OFACScreen. An AML/CFT programme needs those from elsewhere. OFACScreen does not freeze funds and is not connected to goAML or the EOCN.

Questions

Anti-money laundering and countering the financing of terrorism: the rules that make businesses know their customers, spot and report suspicious activity, and refuse to deal with people under sanctions. The UAE's law puts countering proliferation financing under the same heading.
Federal Decree-Law No. 10 of 2025 on anti-money laundering, combating the financing of terrorism and proliferation financing, issued on 30 September 2025. Its Article 41 repealed Federal Decree-Law No. 20 of 2018. Cabinet Resolution No. 134 of 2025 is its executive regulation, and Cabinet Decision No. 74 of 2020 governs targeted financial sanctions.
Financial institutions, designated non-financial businesses and professions and virtual asset service providers, which the Financial Intelligence Unit calls reporting entities. The DNFBPs are real estate brokers and agents, dealers in precious metals and stones, lawyers, notaries, other independent legal professionals and independent accountants, company and trust service providers, and commercial gaming operators. See who counts as a DNFBP.
Not less than five years. For transaction records the period runs from the completion of the transaction or the end of the business relationship. For customer due diligence files, correspondence and suspicious transaction reports it runs from the end of the relationship, the closure of the account, the occasional transaction, a supervisory inspection, an investigation or a final judgment, whichever is latest.
A supervisor can impose administrative penalties on the businesses it supervises: a warning, a fine of AED 10,000 to AED 5,000,000 per violation, a ban from the sector or restrictions on the people responsible. Violating the EOCN's targeted financial sanctions instructions is a separate crime, punishable by imprisonment and a fine of not less than AED 20,000, or either.
It covers one part of AML compliance: sanctions screening. It does not do customer due diligence, PEP checks, transaction monitoring or goAML reporting. See AML software for UAE businesses.

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