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 measures for medium risk and simplified due diligence for low-risk customers where there is no suspicion of money laundering or terrorism financing, with reference to the Ministry's customer risk assessment and due diligence guidance.
Circular No. 6 of 2025 (reference MOET/AML/6/2025), dated 5 August 2025, is a short two-page instruction from the Ministry of Economy and Tourism to the designated non-financial businesses and professions it supervises: real estate brokers and agents, dealers in precious metals and precious stones, auditing and accounting firms, and corporate services providers. It is in force and has no stated end date. Its purpose is to confirm that customer due diligence must be scaled to the customer's assessed risk, and in particular that simplified due diligence is permitted for low-risk customers.
The circular opens by recalling the Ministry's ongoing awareness work on anti-money laundering, counter-terrorist financing and counter-proliferation financing in the DNFBP sector and its previously published guidance on customer risk assessment and enhanced due diligence, and emphasises the importance of implementing customer due diligence in accordance with a sound risk-based approach. It then sets three numbered instructions. First, apply enhanced due diligence for customers identified as high risk. Second, apply customer due diligence, meaning the standard measures, for customers assessed as medium risk, provided there is no suspicion of money laundering or terrorist financing. Third, apply simplified due diligence for customers identified as low risk, again provided there is no suspicion of money laundering or terrorist financing.
The circular explains the policy behind the instruction: a risk-based approach allows a business to allocate its resources and efforts to higher-risk customers while avoiding excessive measures for lower-risk customers, in support of financial inclusion. It closes with links to the Ministry's two relevant guidance documents, on customer risk assessment and on customer due diligence, which set out the risk factors and the content of each level of due diligence; the circular itself does not define those factors or list what simplified measures may consist of. It is signed by the Director of the Anti-Money Laundering and Terrorist Financing Department.
The circular does not cite article numbers or set penalties. Its legal footing is the risk-based customer due diligence duty now found in Article 19 of Federal Decree-Law No. 10 of 2025 and the implementing regulation, Cabinet Resolution No. 134 of 2025, which require DNFBPs to determine the scope of due diligence according to risk. In practical terms it is the Ministry's confirmation that a supervised business will not be criticised for applying lighter measures to a low-risk customer, as long as the risk rating is made and documented first and no suspicion exists. It sits alongside Circular No. 1 of 2026 on high-risk countries, which mandates the enhanced end of the same scale.
Designated non-financial businesses and professions supervised by the Ministry of Economy and Tourism: real estate brokers and agents, dealers in precious metals and precious stones, auditing and accounting firms and corporate services providers, in respect of every customer they onboard or review.
| Paragraph 1 (Preamble) | Recalls the Ministry's awareness efforts and its previously published guidance on customer risk assessment and enhanced due diligence, and emphasises implementing customer due diligence in accordance with a sound risk-based approach. |
| Item 1 | Apply enhanced due diligence measures for customers identified as high risk. |
| Item 2 | Apply standard customer due diligence for customers assessed as medium risk, provided there is no suspicion of money laundering or terrorist financing. |
| Item 3 | Apply simplified due diligence for customers identified as low risk, provided there is no suspicion of money laundering or terrorist financing. |
| Paragraph 2 (Rationale) | States that the risk-based approach lets a business allocate resources to higher-risk customers while avoiding excessive measures for lower-risk customers, in support of financial inclusion. |
| Paragraph 3 (Guidance links) | Directs DNFBPs to the Ministry's guidance documents on customer risk assessment and on customer due diligence for the detail of each level of measures. |
This circular is what lets us run a proportionate onboarding process instead of treating every file as high risk. Our customer risk assessment scores nationality, residence, structure, activity, source of funds and delivery channel; the score determines whether the file goes to simplified, standard or enhanced due diligence, and the circular gives us the Ministry's own authority for that design. For a low-risk client, for example a UAE-resident individual setting up a single-shareholder RAKEZ or Meydan company in a non-cash activity, simplified measures mean identity and ownership verification with a lighter source-of-funds enquiry and a longer review cycle. The two conditions are strict: the rating must be documented before the lighter measures are applied, and any suspicion ends the simplification at once. We use the same framework when drafting AML policies for the accounting, audit and real estate clients we license, so that their inspectors see a documented rationale rather than a blanket approach.
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