Joint guidance of the UAE supervisory authorities for auditors, lawyers, company and trust service providers, dealers in precious metals and stones and real estate agents. It explains risk assessment, customer due diligence, beneficial ownership, suspicious transaction reporting, governance, record-keeping and sanctions compliance. Written under the 2018 law and 2019 regulation, both now repealed; no updated edition found officially.
The AML/CFT Guidelines for Designated Non-Financial Businesses and Professions (Version 6.0, April 2019) are the joint guidance of the UAE supervisory authorities for DNFBPs. They are not legislation: Section 1.3 says that where they conflict with a law or regulation, the law prevails. Their purpose, stated in Section 1, is to provide guidance and assistance to supervised institutions that are DNFBPs in understanding and meeting their obligations. They were written under Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019, both since replaced by Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025; no later edition was found on an official site, so their status is unknown and they should be read as a description of supervisory expectations rather than of current article numbers.
Section 1.2 covers auditors and accountants, lawyers and notaries, company and trust service providers, dealers in precious metals and stones, real estate agents and brokers and other designated businesses, including in free zones, and applies to their boards, management and staff. Part 1 (Sections 2 and 3) describes the legal framework and highlights the core duties: risk assessment, customer due diligence, suspicious transaction reporting, a compliance officer, record keeping and sanctions compliance. Section 3.9 notes the criminal penalties then in force: imprisonment and/or a fine of AED 100,000 to AED 1,000,000 for failing to report, and imprisonment of at least six months and/or AED 100,000 to AED 500,000 for tipping off.
Part 2 (Section 4) sets out the risk-based approach: identify, assess and document money laundering and terrorist financing risk at enterprise and customer level across customer, geography, product and delivery-channel factors, and refresh it regularly and before launching new products. Part 3 covers mitigation. Section 5 requires senior-management-approved internal policies proportionate to the risks. Section 6 details customer due diligence: completion before or during the relationship or before an occasional transaction of AED 55,000 or more; identification of any natural person owning or controlling 25% or more of a legal person, looking through each layer of ownership, aggregating commonly owned small holdings and falling back to senior management; the listed-company exemption; enhanced due diligence for higher risk including PEPs, high-risk countries and non-profit organisations; simplified due diligence for low risk; customer profiles and ongoing monitoring (Sections 6.3.4 and 6.3.5); and no CDD where it would tip off a suspect, with a report to the FIU instead. Section 7 covers suspicious transaction reporting, Section 8 governance (compliance officer, screening, training, audit), Section 9 record keeping and Section 10 international financial sanctions, which it treats as an overview only.
Status: unknown; superseded in its legal references but still the most detailed official explanation of what supervisors expect from corporate service providers.
Designated non-financial businesses and professions in the UAE, including free zones: auditors and accountants, lawyers and notaries, company and trust service providers, dealers in precious metals and stones, real estate agents and brokers, and other designated businesses, together with their boards, senior management and staff. Guidance only; it binds no one where it conflicts with law.
| Section 1.2 | Scope: auditors and accountants, lawyers and notaries, company and trust service providers, dealers in precious metals and stones, real estate agents and brokers and other designated businesses, in the UAE including free zones, and their boards, management and staff. |
| Section 1.3 | Legal status: the guidelines are not legislation; where they conflict with laws or regulations, the laws prevail. |
| Section 3 | Highlights the key statutory duties: enterprise and customer risk assessment, customer due diligence, suspicious transaction reporting, appointment of a compliance officer, record keeping and implementation of sanctions directives. |
| Section 3.9 | Penalties under the 2018 law: imprisonment and/or a fine of AED 100,000 to AED 1,000,000 for failing to report suspicions, and at least six months' imprisonment and/or AED 100,000 to AED 500,000 for tipping off. |
| Section 4 | Risk-based approach: identify, assess and document risk at enterprise and customer level using customer, geographic, product and channel factors, and update the assessment regularly and before new products or technologies. |
| Section 5 | Internal policies, controls and procedures must be approved by senior management, reviewed, and proportionate to the risks identified. |
| Section 6.2 | Beneficial ownership: identify any natural person who owns or controls 25% or more, look through each layer of ownership, aggregate commonly owned holdings, apply the listed-company exemption and fall back to senior management where no owner is found. |
| Section 6.3 | Customer due diligence: identification and verification from original official documents, sanctions and adverse-information screening, understanding the purpose of the relationship, source-of-funds checks for higher risk, customer profiles and ongoing monitoring. |
| Section 7 | Suspicious transaction reporting: report suspicions to the competent authority, keep reports confidential and do not tip off the customer. |
| Section 8 | Governance: a compliance officer appointed and approved by the supervisor, staff screening and training, group oversight, independent audit and senior management responsibility. |
The guidelines impose none themselves. Section 3.9 recites the 2018 law's criminal penalties for failing to report (imprisonment and/or AED 100,000 to AED 1,000,000) and tipping off (at least six months and/or AED 100,000 to AED 500,000); the current equivalents are Articles 28 and 29 of Federal Decree-Law No. 10 of 2025 and the DNFBP fine schedule in Cabinet Resolution No. 71 of 2024.
We read these guidelines alongside the 2025 law and regulations when we design or inspect an AML programme, because they explain how a supervisor expects the statutory words to be applied: what a documented enterprise risk assessment looks like, how to build a customer profile that monitoring can be measured against, when to look through a holding company and when to aggregate small shareholdings. Our own client risk assessment form follows the Section 4 factors, and our CDD checklist follows Section 6.3, including the four-eyes review of foreign documents the guidance recommends. What we do not do is cite the guidelines as law or copy their article references: every legal citation in a client manual goes to Federal Decree-Law No. 10 of 2025, Cabinet Resolution No. 134 of 2025 and Cabinet Resolution No. 71 of 2024, with the guidelines noted as supervisory expectation.
AML Law 2018 (repealed)
The former UAE AML/CFT law, in force from October 2018, which first brought designated non-financial businesses and professions under federal AML supervision and goAML re…
AML Implementing Regulation 2019 (repealed)
The former executive regulation of the 2018 AML law. It defined the DNFBP categories (including trust and company service providers), set customer due diligence, record-k…
AML/CFT/CPF Law 2025
The UAE's principal AML law in 42 articles. It criminalises money laundering, terrorism and proliferation financing, imposes risk assessment, customer due diligence, reco…
AML Executive Regulations 2025
The executive regulations of the 2025 AML law, replacing Cabinet Decision No. 10 of 2019. They set the detailed requirements for financial institutions, DNFBPs and VASPs:…
DNFBP AML Administrative Penalties 2024
Sets the schedule of administrative fines for DNFBPs supervised by the Ministry of Justice and the Ministry of Economy (lawyers, notaries, auditors, accountants, real est…
Targeted Financial Sanctions Regulation
Governs the UAE Local Terrorist List and the implementation of UN Security Council sanctions: listing and delisting, the role of the Executive Office for Control and Non-…
MoET Circular 6/2025 – Risk-Based CDD
Circular MOET/AML/6/2025 directing DNFBPs under Ministry supervision to scale customer due diligence to risk: enhanced due diligence for high-risk customers, standard mea…
goAML Registration Rules (DNFBPs)
The Ministry's official page and step-by-step guide on mandatory goAML registration for the DNFBPs it supervises: real estate brokers, auditors and accountants, dealers i…
Whether you are establishing a new venture, restructuring an existing enterprise, or exploring residency pathways — we are here to advise.
Arrange a Consultation →