Anti-money laundering programme design, customer due diligence, suspicious transaction reporting, and goAML registration.
UAE anti-money laundering regulations impose comprehensive obligations on all businesses operating within the country. These obligations encompass customer due diligence (CDD), enhanced due diligence (EDD) for higher-risk relationships, ongoing monitoring of business relationships, suspicious transaction reporting (STR) through the goAML platform, and record-keeping requirements.
For Designated Non-Financial Businesses and Professions (DNFBPs) — which include real estate agents, precious metal dealers, and corporate service providers — these obligations are particularly stringent. Non-compliance carries severe penalties including substantial fines, licence suspension, and criminal prosecution.
Polaris designs and implements AML/KYC compliance programmes that satisfy regulatory requirements while remaining operationally practical. We understand that compliance is not a one-time exercise but an ongoing discipline that must be embedded in the client's business processes.
Answers drawn from the published rules of the UAE authorities and regulators. Each answer links to its official source. Last reviewed 25 October 2026.
Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing. The UAE legislation portal records it as issued on 30 September 2025 and in force from 14 October 2025, and Article 41 repeals Federal Decree by Law No. (20) of 2018. Its Executive Regulations are Cabinet Resolution No. (134) of 2025, in force from 14 December 2025, which carry the detailed rules on due diligence, reporting, record-keeping and the compliance officer. Many guidance pages still cite the 2018 law and the 2019 regulations, so your AML manual should now be re-referenced to the 2025 instruments and checked against their substance. We carry out this re-alignment for clients as a fixed-scope exercise.
Sources: UAE Legislation portal (Government of the UAE) — Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (English text); UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (accessed 24 October 2026)
It is if it carries on an activity listed in Article 3 of Cabinet Resolution No. (134) of 2025. The Ministry of Economy's goAML guidance puts the commercial categories plainly: real estate brokers and agents, auditing or accounting firms, dealers in precious metals or stones, and company service providers, meaning firms that provide company establishment or business administration services to third parties. Article 3 also lists lawyers, notaries and other independent legal professionals handling client transactions. For company service providers the regulation is specific: acting as an agent in the incorporation of legal persons, arranging directors or secretaries, providing a registered office or business address, and arranging nominee shareholders all qualify. If any of this describes your business, the full AML framework applies. We confirm the classification first.
Sources: UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of the Anti-Money Laundering Decree-Law (English text); UAE Ministry of Economy and Tourism — goAML Suspicious Transaction Reporting System in the UAE (accessed 24 October 2026)
Yes, if it is a DNFBP. The Ministry of Economy, which supervises DNFBPs, states that all DNFBPs were required to register on the goAML portal, the Financial Intelligence Unit's reporting system, and warns that failure to register may result in severe penalties invoked by the Ministry. Registration needs an authorisation letter from the company, a copy of the authorised person's passport, visa and Emirates ID, a copy of the trade licence and the Google Authenticator app. Cabinet Resolution No. (71) of 2024 prices failure to register at AED 50,000 to AED 200,000, and in August 2023 the Ministry suspended 50 unregistered DNFBPs for three months. We prepare the registration, set up the reporting officer's access and keep the profile current when your licence or officers change.
Sources: UAE Ministry of Economy and Tourism — goAML Suspicious Transaction Reporting System in the UAE; UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (71) of 2024 Regulating Violations, Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating Financing of Terrorism Subject to the Control of Ministry of Justice and Ministry of Economy (English text) (accessed 24 October 2026)
Article 17 of Federal Decree by Law No. (10) of 2025 lets a supervisory authority impose an administrative fine of not less than AED 10,000 and not exceeding AED 5,000,000 for each violation, alongside warnings, restrictions on managers and licence suspension or revocation. For DNFBPs under the Ministry of Economy or Ministry of Justice, Cabinet Resolution No. (71) of 2024 sets the amount per breach: AED 100,000 to AED 500,000 for failing to submit a suspicious transaction report promptly, and AED 50,000 to AED 200,000 for failing to appoint a compliance officer or keep records. The Ministry may double a fine when the violation is repeated. In 2023 alone the Ministry of Economy reported fines of about AED 76.9 million on 225 DNFBP companies. Our gap reviews follow this schedule.
Sources: UAE Legislation portal (Government of the UAE) — Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (English text); UAE Ministry of Economy and Tourism — Ministry of Economy suspends operations of 50 DNFBP establishments for 3 months for failure to register in goAML system (accessed 24 October 2026)
Report immediately and say nothing to the client. Article 18 of Federal Decree by Law No. (10) of 2025 requires a DNFBP that suspects, or has reasonable grounds to suspect, that a transaction or funds are linked to crime to notify the Financial Intelligence Unit without delay, regardless of the value; the Executive Regulations require the report to go through the Unit's electronic system, goAML. There is no minimum amount. Warning the customer or anyone else that a report is being considered is an offence under Article 29, punishable by imprisonment and/or a fine of not less than AED 50,000. Failing to report promptly also carries an administrative fine of AED 100,000 to AED 500,000. We help compliance officers assess red flags, document the decision and file correctly.
Sources: UAE Legislation portal (Government of the UAE) — Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (English text); UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (71) of 2024 on AML/CFT administrative penalties for entities under the Ministry of Justice and Ministry of Economy (English text) (accessed 24 October 2026)
Yes. Article 22 of Cabinet Resolution No. (134) of 2025 requires financial institutions, DNFBPs and virtual asset service providers to appoint a Compliance Officer at management level who has the independence to do the job. The officer owns the firm's AML programme day to day and is the point of contact for the Financial Intelligence Unit and the supervisor. Failing to appoint an officer with the appropriate competence is a breach in its own right, fined at AED 50,000 to AED 200,000 under Cabinet Resolution No. (71) of 2024. In a small firm this is often the owner or general manager; the regulation does not allow the role to sit below management level. We design the role, train the appointee and support them with screening and reporting procedures.
Sources: UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of the Anti-Money Laundering Decree-Law (English text); UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (71) of 2024 on AML/CFT administrative penalties for entities under the Ministry of Justice and Ministry of Economy (English text) (accessed 24 October 2026)
At least five years. Article 25 of Cabinet Resolution No. (134) of 2025 requires all records, documents, instruments and data on domestic and international transactions to be retained for not less than five years from the completion of the transaction, and Article 19 of Federal Decree by Law No. (10) of 2025 requires them to be available to the competent authorities immediately on request. In practice that means identification documents, screening results, source-of-funds evidence and the reasoning behind any report filed or not filed. Failing to keep any of the records is fined at AED 50,000 to AED 200,000 under Cabinet Resolution No. (71) of 2024. We structure client files so that every item an inspector may ask for can be produced the same day.
Sources: UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of the Anti-Money Laundering Decree-Law (English text); UAE Legislation portal (Government of the UAE) — Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (English text) (accessed 24 October 2026)
Not for a business relationship. Article 7 of Cabinet Resolution No. (134) of 2025 requires customer due diligence upon the commencement of a business relationship, whatever the amount. Thresholds apply only to one-off dealings: occasional transactions amounting to or exceeding AED 55,000 and, for financial institutions, occasional wire transfers of AED 3,500 or more. Due diligence has to be completed before the relationship is established, not back-filled afterwards: Cabinet Resolution No. (71) of 2024 fines a failure to undertake the necessary measures before establishing the business relationship at AED 50,000 to AED 200,000. We build the onboarding checklist so that identification, verification and screening are completed and evidenced before any work starts on the file.
Sources: UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of the Anti-Money Laundering Decree-Law (English text); UAE Legislation portal (Government of the UAE) — Cabinet Resolution No. (71) of 2024 on AML/CFT administrative penalties for entities under the Ministry of Justice and Ministry of Economy (English text) (accessed 24 October 2026)
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