CMA Guidance of 2021 · UAE Federal
Joint supervisory guidance of June 2021 drawing on 2020 to 2021 examinations of financial institutions: governance, three lines of defence, policies, training, transaction monitoring, sanctions screening, suspicious transaction reporting and record keeping.
The June 2021 Anti-Money Laundering and Countering Terrorist Financing Guidelines are joint supervisory feedback from all UAE AML supervisors. Drawing on inspections carried out between January 2020 and May 2021, they set out side by side what supervisors judged satisfactory and unsatisfactory in the AML/CFT and sanctions frameworks of financial institutions and DNFBPs.
The guidance was issued jointly by the Central Bank of the UAE, the DFSA, the FSRA, the Securities and Commodities Authority (now the Capital Market Authority) and the Ministries of Justice and of Economy. It applies to all financial institutions and, where applicable, DNFBPs licensed, registered or regulated by them. It rests on FATF Recommendation 34, Federal Decree-Law No. 20 of 2018, Cabinet Decision No. 10 of 2019 and Cabinet Decision No. 74 of 2020.
For financial institutions, Section 2 covers governance and management oversight (risk assessment, the three lines of defence, policies and procedures, training and the compliance officer or MLRO), onboarding and monitoring (customer risk rating, data quality and due diligence), monitoring and surveillance (transaction monitoring, sanctions screening and suspicious transaction reporting) and record keeping. Examples of unsatisfactory practice include risk assessments that ignore the National Risk Assessment, generic training, customer risk ratings treated as a one-off exercise, monitoring tuned only by an outside vendor, weak fuzzy-matching logic and records that cannot be retrieved.
Section 3 covers DNFBPs (real estate brokers and agents, dealers in precious metals and stones, and lawyers, notaries and other legal professionals): compliance culture, risk assessment, due diligence, policies, internal controls and suspicious activity reporting. The guidance creates no new obligations and carries no penalties. Its legal references predate Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, but the expectations remain a practical benchmark.
All financial institutions and, where applicable, DNFBPs licensed, registered or regulated by the Central Bank, the DFSA, the FSRA, the Securities and Commodities Authority (now CMA) and the Ministries of Justice and of Economy.
English official text in 5 provisions. Open the full text or jump to a provision:
| Section 1 | Purpose and scope: joint guidance under FATF Recommendation 34, based on common themes supervisors observed in inspections from January 2020 to May 2021, applying to FIs and, where applicable, DNFBPs. |
| Section 2 – Governance Framework | Sets satisfactory and unsatisfactory practice for ML/FT risk assessment, three lines of defence, policies and procedures, training and the compliance officer, including linking risk assessment to the National Risk Assessment and risk appetite. |
| Section 2 – On-boarding and Continuous Monitoring | Covers customer risk rating methodology, KYC data quality and due diligence; flags one-off risk ratings, expired KYC documents and weak identification of ultimate beneficial owners as unsatisfactory. |
| Section 2 – Monitoring & Surveillance | Covers transaction monitoring, sanctions screening and STR reporting; the institution remains responsible for its monitoring system even when an external vendor tunes it, and must define timeframes for reporting STRs. |
| Section 2 – Record Keeping Practices | Records must be retained and retrievable without delay, including where held by third parties or a parent company, with documents linked to the customer file. |
| Section 3 | DNFBP findings for real estate brokers, precious metals and stones dealers and legal professionals: compliance culture, risk assessment, due diligence including source of wealth, policies, internal controls over cash and suspicious activity reporting. |
Polaris is a corporate service provider and a DNFBP, so this joint feedback applies to us as well as to our regulated clients. We use the satisfactory-practice columns to test our own AML/CFT framework: a risk assessment that reflects the National Risk Assessment, documented source-of-wealth checks, clear ownership mapping for corporate clients and records we can retrieve on request. For clients setting up licensed businesses, we point their compliance advisers to the same benchmarks and keep the corporate and UBO records our side holds in a form an examiner would accept.
| Cites | AML Implementing Regulation 2019 (repealed) · Targeted Financial Sanctions Regulation · AML Law 2018 (repealed) |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
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UAE DNFBP AML/CFT Guidelines
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