Vikas Dhingra
Chief Financial Officer · Tax & Structuring
UAE Compliance —
AML, ESR, UBO
Anti-Money Laundering, Economic Substance Regulations, Ultimate Beneficial Ownership and goAML registration — managed end-to-end by Avyanco's regulatory practice.
- AML / CFT
- ESR Filings
- UBO Register
- goAML Registration
- Sanctions Screening
The Compliance Layer Most Groups Underestimate
UAE compliance covers Anti-Money Laundering (AML/CFT), Economic Substance Regulations (ESR), Ultimate Beneficial Ownership (UBO) and goAML registration. Designated Non-Financial Businesses and Professions operate under the Federal AML/CFT framework, most entities file annual UBO returns under Cabinet Decision No. 109 of 2023, and ESR applies to entities undertaking relevant activities. Avyanco manages this regulatory stack end-to-end.
UAE compliance is no longer a one-off setup task. Designated Non-Financial Businesses and Professions (DNFBPs) operate under the Federal AML/CFT framework. Most UAE entities have annual Ultimate Beneficial Ownership filings under Cabinet Decision No. 109 of 2023. Economic Substance Regulations apply to entities undertaking relevant activities. Sanctions screening, transaction monitoring, AML policies and goAML portal registration are now table-stakes for licensed activities — and the penalty regime is unforgiving.
Avyanco's compliance practice covers the full regulatory stack — AML programme design, AML officer support, ESR notification and reporting, UBO register maintenance, goAML registration, sanctions screening setup and policy documentation. We work with mainland and free zone entities and with regulated sectors that face additional FSRA, DFSA or SCA obligations. Engagements are scoped to the specific risk profile — not boilerplated.
The Avyanco Advantage
Compliance done as a programme, not a checklist.
AML Programme Design
Risk-based AML policy, KYC procedures, transaction monitoring framework and AML officer support — built to UAE Federal AML/CFT standards.
UBO Register Management
Ultimate Beneficial Ownership registration, annual filings and change notifications under Cabinet Decision No. 109 of 2023.
ESR Scoping & Filing
Economic Substance Regulations relevant-activity test, annual notification and ESR report preparation for entities in scope.
goAML Registration
goAML portal registration for DNFBPs, ongoing STR / SAR filing support and UAE FIU correspondence.
Sanctions Screening
Sanctions screening setup against UN, OFAC, EU, UK and UAE local lists — integrated with onboarding KYC and ongoing monitoring.
Bank-Facing Readiness
AML programme documentation, ESR position and UBO disclosure packaged for UAE bank ongoing KYC and correspondent banking.
Meet Our Specialists
Partner-led compliance practice — Vikas Dhingra leads AML, ESR and UBO alongside Avyanco's tax and audit team.
Why Groups Choose Avyanco for Compliance
Three things that come up in every compliance engagement.
Risk-Based Programmes
AML, ESR and UBO programmes scaled to the entity's actual risk profile — not boilerplate documentation.
Penalty Avoidance
Filings tracked against deadlines, change-of-control triggers monitored, penalty exposure reduced.
Bank-Facing Documentation
Compliance documentation packaged so UAE bank ongoing KYC and correspondent banking due diligence go through cleanly.
Compliance Services
Four connected workstreams covering AML, ESR, UBO and goAML.
Risk Advisory (GRC)
Enterprise risk, internal-controls design and the UAE regulatory stack — AML, Economic Substance, UBO, sanctions and data protection — under one governance framework.
Read moreAML Compliance & DNFBP Support
Federal AML/CFT framework — risk-based AML policy, MLRO support, goAML registration, STR filing and sanctions screening.
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Corporate Tax Compliance
Corporate Tax compliance crosses with ESR and Transfer Pricing — handled together to keep the multi-regime view coherent.
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Audit & Assurance
Statutory audit ties into compliance file review — UBO disclosures, ESR notifications and AML controls examined at audit.
Read moreUBO Filing & Compliance
Beneficial-ownership identification, registers and filing under Cabinet Decision 109/2023 (which replaced 58/2020) — kept current as ownership changes, alongside ESR and Corporate Tax.
Read moreWhat Clients Say
Recent feedback from groups Avyanco runs UAE compliance work for.
We had an excellent experience working with this company for our ADGM company setup in Abu Dhabi.
Read more — Nikhil Nadanga's review on GoogleN
Nikhil Nadanga25 May 2026
I have been dealing with Akshta for more than a year now and she has been very professional.
Read more — Sherif Ayub's review on GoogleS
Sherif Ayub24 May 2026
In so far as the emigration process can ever be made easy, Avyanco achieves exactly this.
Read more — Sheru George's review on GoogleS
Sheru George12 May 2026
We are very satisfied with Avyanco's support for Nanasu Realty — especially across AML compliance, accounting, and company setup.
Read more — Purushottam Mukkundi's review on GoogleP
Purushottam Mukkundi6 May 2026
I've used the services of Avyanco twice over the past 3 years for visa processing, and they have never failed to impress me.
Read more — Dominic Pinto's review on GoogleD
Dominic Pinto11 May 2026
I had an excellent experience with Avyanco Business Setup Consultancy for both my company formation and family dependent visa process in the UAE.
Read more — Eder Schaphauser Ziomek's review on GoogleE
Eder Schaphauser Ziomek29 April 2026
UAE Compliance — Frequently Asked Questions
Common questions about UAE AML, ESR and UBO compliance.
What is a DNFBP and does it apply to my business?
DNFBP stands for Designated Non-Financial Business and Profession. The UAE Federal AML/CFT framework designates specific sectors as DNFBPs — including real estate brokers and agents, dealers in precious metals and stones, auditors, corporate service providers, lawyers and notaries. DNFBPs must register on the goAML portal, implement a risk-based AML programme, appoint a compliance officer and file STRs / SARs as required. Avyanco confirms DNFBP scope at the engagement stage.
What is UBO and who has to file it?
Ultimate Beneficial Ownership refers to the natural person who ultimately owns or controls an entity. Under Cabinet Decision No. 109 of 2023, most UAE entities must maintain a UBO register and file changes with the relevant licensing authority. The threshold for UBO disclosure is typically 25% direct or indirect ownership, or other control rights. Avyanco maintains UBO registers and handles change-notification filings.
What is Economic Substance Regulations (ESR)?
ESR requires UAE entities undertaking 'relevant activities' (banking, insurance, investment fund management, lease-finance, headquarters, shipping, holding company, intellectual property, distribution and service centres) to demonstrate adequate economic substance in the UAE. In-scope entities file annual ESR notifications and full ESR reports. The relevant-activity test is the first scoping question — Avyanco runs it before any filing work.
What is the goAML portal?
goAML is the UAE Financial Intelligence Unit's online reporting system for AML/CFT obligations. DNFBPs, financial institutions and other obliged entities register on goAML and use it to file Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs) and other AML notifications. Registration is mandatory for in-scope entities.
What are the penalties for AML non-compliance?
UAE AML penalty schedules are set out under the Federal AML/CFT framework and run from financial penalties through to licence suspension or revocation. Penalties apply to failures around AML policy implementation, transaction monitoring, STR filing, sanctions screening, record-keeping and AML officer appointment. Avyanco's programme design is built to keep entities outside the penalty zone.
How does compliance interact with Corporate Tax?
Compliance and Corporate Tax overlap in several places — ESR relevant-activity tests interact with QFZP qualifying-activities tests, UBO disclosures inform related-party tracking for Transfer Pricing, AML KYC files inform source-of-funds disclosures for tax. Avyanco runs the engagements together so the cross-regime view stays consistent.
Sources & official references
Abu Dhabi Global Market (ADGM) · Federal Tax Authority (FTA) · UAE Ministry of Finance · UAE Ministry of Economy
Verification & independence
Content prepared from publicly available UAE Ministry of Economy, UAE Financial Intelligence Unit, Federal Tax Authority (FTA), Cabinet Decision No. 109 of 2023 (UBO) and Federal Decree-Law No. 10 of 2025 (AML/CFT, which replaced No. 20 of 2018) guidance as of June 2026. Avyanco Business Consultancy LLC is independent of all UAE government authorities and not affiliated with any government agency.
AML / CFT obligations, ESR relevant-activity tests, UBO disclosure thresholds and penalty schedules evolve. Always confirm the current rules for your specific entity directly with the Ministry of Economy, the UAE FIU, the FTA or a qualified compliance advisor before acting on any fact on this page.
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