A Guide To Anti Money Laundering UAE | 2026

The United Arab Emirates (UAE) has solidified its position as a world leader in trade, innovation, and finance. Protecting the financial system from illegal activity, especially money laundering in the UAE and terrorist financing, is a crucial duty that comes with this prestige.

The anti money laundering UAE environment is more demanding, technologically sophisticated, and stricter than it has ever been as we approach 2026. Driven by the international standards established by the Financial Action Task Force (FATF) and the recent introduction of improved legislation (such as Federal Decree-Law No. 10 of 2025, which repeals the previous 2018 law), compliance is now an essential component of maintaining business licenses and corporate integrity rather than just avoiding fines.

The New Reality of AML in UAE (2026 Focus)

The stakes for businesses have significantly increased due to the UAE’s new legal framework. Ignorance is no longer a defense because the emphasis has shifted from simple adherence to a “should have known” standard of accountability.

1. Key Legal Changes and Increased Enforcement

• Reduced Evidentiary Threshold – Prosecutors are no longer required to demonstrate that an individual had “actual knowledge” that funds were illegal under the new AML UAE law. It is sufficient to have either circumstantial or sufficient evidence, and knowledge can be deduced from “factual and objective circumstances.” This implies that an individual may be held accountable if they should have known the funds were illegal.

• Extension to New Offenses – The financing of weapons of mass destruction, or Proliferation Financing (PF), is expressly illegal under the law. Businesses in the manufacturing, logistics, and trade finance sectors must perform Enhanced Due Diligence (EDD) to determine whether any products or materials could be used for illegal purposes. This has significant ramifications for these industries.

• Complete Inclusion of Virtual Assets – Offenses committed via digital systems, virtual assets, and encryption technologies are specifically addressed by the new framework. Now completely regulated, virtual asset service providers (VASPs), like cryptocurrency exchanges and wallet providers, are required to put in place bank-grade AML controls.

• Serious Penalties – Legal entities found guilty of money laundering may be fined up to AED 100 million (previously capped at AED 50 million). For violations, managers and agents may also be held personally criminally liable.

2. Who Must Comply? (The Scope of AML UAE)

The regulations extend well beyond conventional banks. The anti money laundering UAE laws must be strictly followed by a broad category known as Designated Non-Financial Businesses and Professions (DNFBPs).

• Real estate – Developers, brokers, and agents engaged in the purchase and sale of real estate.

• Dealers in Precious Metals and Stones (DPMS) – Dealers in Precious Metals and Stones (DPMS) include manufacturers, traders, refiners, and jewelers who deal in gold, silver, diamonds, and other precious commodities.

• Legal & Accounting Firms – Notaries, auditors, accountants, and legal advisors who assist clients with specific financial or asset-related transactions.

• Corporate Service Providers (CSPs) – Businesses that offer director, formation, or registered office services are known as corporate service providers (CSPs).

The Six Pillars of AML Compliance for Businesses

Regardless of which industry you’re in, the compliance framework for AML in UAE must be constructed using these six base components.

1. Appointment of a Compliance Officer (MLRO)

Every firm that is under regulation must appoint a Compliance Officer for Anti-Money Laundering (AML), who is usually referred to as Money Laundering Reporting Officer (MLRO). The appointed person will be the chief contact person for the company with the regulatory authorities and will personally supervise the compliance of the company’s policy.

• Role – Supervising internal procedures, training personnel, and electronically filing all reports (STRs/SARs) with the Financial Intelligence Unit (FIU).

2. Performing a Business Risk Assessment (BRA)

This is at the heart of the anti money laundering UAE framework. You will have to identify the exact risks of Money Laundering (ML) and Terrorism Financing (TF) that your enterprise is exposed to.

What to Consider –

• Customer Risk – Are you dealing with high-risk customers (e.g., Politically Exposed Persons (PEPs) or residents of countries with a high risk of money laundering)?

• Product/Service Risk – Is it possible for you to accept cash, process cross-border transactions with low detection of ownership (e.g., trust creation)?

• Geographic Risk – Are you conducting business in or with regions prone to money laundering and that have inadequate AML safeguards?

Outcome – The BRA will determine whether you need to apply Standard or Enhanced diligence to each customer and transaction.

3. Drafting Clear Policies and Procedures

Your risk assessment must be documented in the form of written internal policies and procedural manuals that are not only practicable but also very easy to follow by the front-line staff.

Must-Have Documentation –

• Procedures for customer acceptance and due diligence.
• Monitoring thresholds and steps to escalate transactions.
• Protocols for record-keeping and retention (documents have to be stored for a minimum of five years).

4. Customer Due Diligence (CDD) and KYC

Know Your Customer (KYC) and Customer Due Diligence (CDD) are the terminologies used to refer to the processes of identifying and verifying clients.

Key Requirements –

• Identity Verification – Obtaining and validating passports, Emirates IDs, trade licenses, etc.

• Ultimate Beneficial Owner (UBO) Identification – Identifying the real person who ultimately owns or controls the company (usually possessing 25% or more of the shares or voting rights).

• Funds/Wealth Source – Knowing the background of the client’s money, especially for high-risk transactions.

• Sanctions Screening – Constantly checking the clients and the parties involved in a transaction against local and international sanctions lists.

5. Transaction Monitoring and Reporting (goAML)

In the UAE, there is a continuous process of monitoring that is indispensable to the detection of money laundering.

Monitoring – The firms will have to keep a check on the transactions, measuring them against predetermined thresholds and also against the client’s habitual behavior. The transactions attracting attention will be the ones involving cash payments that are not easily explained and have no apparent economic purpose or sudden, high-value transactions that are unexplained.

goAML Registration – It is essential for all the regulated organizations to be registered on the goAML platform of the UAE Financial Intelligence Unit (FIU) for AML purposes. This is the official channel for reporting –

• STRs (Suspicious Transaction Reports)
• SARs (Suspicious Activity Reports)

The Process – The registration on goAML is a secure two-step process: first, registering on the Service Access Control Manager (SACM) will provide the login credentials, then setting up the Google Authenticator for two-factor verification, and finally, completing the company profile on the goAML portal itself.

6. Staff Training and Record Keeping

The compliance programs’ strength is dependent on the personnel who implement them.

• Training – The entire workforce who are involved in different positions ranging from the receptionist to the top management must be given regular training on the latest risks and red flags that are specific to their role in A Money Laundering (AML), and that also covers the already mentioned red flags.

• Record Keeping – All papers, KYC files, training records, and STR filings should be kept immaculately for a minimum of five years and should also be available quickly for regulator audits.

Partnering for Compliance – Arabian Wingz

Steering the exact needs of anti money laundering UAE law, particularly with the ongoing regulatory modifications, can be overwhelming for most companies. Outsourcing or looking for professional guidance is an affordable way to confirm full adherence and bypass severe fines.

Arabian Wingz is a key service provider with expertise in AML compliance UAE, delivering top-notch solutions that confirm local businesses fulfill and surpass the updated conditions for 2026.

How Arabian Wingz Helps Your Business –

1. Full AML Compliance Setup – They craft and implement unique AML strategies, which encompass the establishment of company policies and procedures, the writing of manuals, and the processing of KYC/CDD workflows that are specifically aligned with your business’s risks and the particular local regulatory climate.

2. goAML Registration & Reporting – Arabian Wingz takes care of the whole process for the mandatory AML registration on the goAML website and also helps in the precise and timely submission of reports (STRs/SARs) to the FIU.

3. Independent Audits and Health Checks – They perform a health check of your AML/CFT system and conduct an independent audit, which will lead you to the gaps in your current setup and will also give you straightforward and practical suggestions on how to prepare for a regulatory inspection.

4. Managed Services – Arabian Wingz can act as the external MLRO or offer managed KYC/CDD services to handle compliance on a day-to-day basis through specialists if the business is small or is one of those that prefer to outsource.

By employing the know-how of Arabian Wingz, your company will be able to move from being a fine-worrier to a confident player in the UAE’s strong and transparent financial system.

Conclusion

The AML in UAE framework establishes a clear and unwavering resolve by the nation to safeguard its financial integrity and promote transparency. The introduction of further legislation, coupled with more stringent penalties and lower thresholds of evidence required, has elevated the necessity for all regulated businesses to be proactively compliant with AML legislation in the UAE.

As the GoAML initiative has introduced the requirement for all entities to register their AML activity electronically, through CDD (Customer Due Diligence)/KYC (Know Your Customer) executor provisions at each step, they will all aid in protecting the business as well as the global reputation of the UAE.

Therefore, it is imperative to embrace these new requirements; develop a complete AML compliance program and forge strategic alliances with qualified professionals capable of assisting your firm in securing your financial future in the ever-changing UAE economy.

Frequently Asked Questions (FAQS)

1. What is anti-money laundering in the UAE?

Anti-money laundering or AML in UAE refers to the laws and regulations that are established to prevent illegal money activities. These strict rules are for businesses, like banks, real estate, and others, to stop crimes like money laundering, fraud, and terrorism financing. Businesses in high-risk sectors must monitor transactions and instantly report suspicious behavior using the goAML system. Not complying with AML laws set to keep the financial system clean in the country results in hefty penalties and legal issues. 

2. Who needs to register for AML in the UAE?

Financial institutions, like banks, insurance companies, exchange houses, and others regulated by the Central Bank, need to register for AML in UAE. Real estate brokers, dealers in precious metals and stones, lawyers, accountants, and others known as DNFBs also need to comply. All these businesses must register on the goAML portal, which is managed by the UAE’s FIU. 

3. How to report money laundering in UAE?

When you detect any unusual transaction and activity, you need to immediately report the incident through the UAE’s goAML portal. All the registered businesses need to submit Suspicious Transactions Reports to the country’s FIU. By submitting STRs, you can help authorities investigate and prevent financial crimes. Timely reporting of suspicious activity is mandatory under the AML law. 

4. What is the new AML law in UAE?

The UAE AML framework is based on Federal Decree-Law No. 20 of 2018, along with recent updates that were later announced. This law now covers CPF and has introduced new offenses, including those linked with virtual assets. The new updates have lowered the evidence thresholds and increased penalties for both companies and individuals. Businesses must regularly update their AML policies to stay compliant.

5. Which entities are regulated by the AML laws in the UAE?

UAE AML laws apply to banks, financial institutions, and DNFBPs. Real estate agents, law firms, jewelers, accountants, and VASPs are closely monitored by the authorities. Whether you run a mainland, free zone, or offshore company in these high-risk sectors, you need to follow all AML rules properly.

6. What are the main requirements of the UAE AML law for businesses?

Businesses on which UAE AML laws are applied must verify their customer identities and perform strict CDD. They must maintain proper transactions and customer records and instantly report any suspicious activities. They must train their staff on AML and CFT obligations. They are required to appoint an AML compliance officer and implement strict internal control policies.