AML Compliance for DNFBPs in the UAE

The UAE’s anti-money laundering framework (Federal Decree-Law No. 20 of 2018 and its executive regulations) places direct obligations on Designated Non-Financial Businesses and Professions (DNFBPs): real estate brokers and agents, dealers in precious metals and stones, auditors and accountants, corporate service providers and company formation agents, and lawyers and notaries handling client transactions. These businesses must register on the goAML portal, appoint a compliance officer, assess their risks, verify their customers and report suspicious transactions. Dawn Consultancy builds and maintains the compliance programme for DNFBPs in Dubai and across the UAE, and acts as outsourced compliance officer where the business has no suitable in-house person.

What DNFBPs must have in place

1. goAML registration with the Financial Intelligence Unit, and registration with the relevant supervisory authority (Ministry of Economy for most mainland DNFBPs; the free zone authority for free zone DNFBPs)
2. A compliance officer approved by the supervisory authority, with the authority and independence to act
3. A written AML/CFT policy covering customer due diligence, risk assessment, record keeping, reporting and training
4. Enterprise risk assessment identifying money laundering and terrorist financing risks by customer type, product, delivery channel and geography, updated at least annually
5. Customer due diligence (KYC) on every customer before the business relationship starts, with enhanced due diligence for politically exposed persons, high-risk countries and complex ownership structures, and identification of the ultimate beneficial owner
6. Sanctions screening of customers and transactions against the UAE local terrorist list and UN Security Council lists, with immediate freezing and reporting of matches
7. Suspicious transaction reporting through goAML, and specific reports for real estate (REAR) and precious metals dealers (DPMSR) above the cash thresholds
8. Record keeping for at least five years after the end of the relationship or the transaction
9. Staff training at onboarding and annually, with attendance records
10. Independent review of the programme’s effectiveness

Penalties

The Ministry of Economy and free zone supervisors carry out inspections and impose administrative penalties ranging from AED 50,000 to AED 5 million per violation, with licence suspension or cancellation for repeat or serious breaches. Common findings include no goAML registration, no appointed compliance officer, KYC files with expired documents, no evidence of sanctions screening, and no risk assessment on file.

Our AML services

• goAML and supervisory authority registration
• Drafting of the AML/CFT policy and procedures manual tailored to the business
• Enterprise and customer risk assessment methodology and initial assessment
• KYC file templates, onboarding checklists and a remediation review of existing customer files
• Sanctions screening set-up and periodic re-screening
• Outsourced compliance officer (MLRO) service
• Annual staff training with certificates of attendance
• Independent AML audit and inspection readiness review
• Representation during supervisory authority inspections and penalty appeals

Frequently asked questions

My real estate brokerage is small. Am I really a DNFBP?
Yes. Size does not matter; the activity does. All licensed real estate brokers and agents are DNFBPs and must register on goAML.

Can the owner be the compliance officer?
The compliance officer can be an owner or employee, but must have the required knowledge and be approved by the supervisory authority. Many small firms appoint an external compliance officer to meet the competence requirement.

What is the cash threshold for reporting?
Real estate transactions involving cash of AED 55,000 or more, and precious metals and stones transactions of AED 55,000 or more in cash, must be reported through goAML even where there is no suspicion.

Do I need to screen every customer against sanctions lists?
Yes, before onboarding and on an ongoing basis whenever the lists are updated. Screening records must be retained.

Get compliant

Email info@dawnconsultancy.com, call +971 55 441 1036, or request a call back. Related: UBO compliance and audit services.