AML/CFT Policies and Procedures in UAE
Avyanco develops the AML/CFT policies and procedures in the UAE for your business and addresses the regulatory obligations. Our services also manage financial crime risks and build effective compliance controls.
- 11,500+ businesses supported
- DET licence #909402
- AML/CFT policies tailored to your activity
AML/CFT Compliance Requirements for UAE Businesses
AML policy in the UAE is beneficial for business, because it helps to identify, prevent and manage the terrorist financing and money laundering risks. Drafting policy includes accurate documentation, internal controls and risk assessments.
Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 establish these policy regulations in the UAE. If you want to draft the compliant AML/CFT policies and procedures for your business, then Avyanco is your right partner.
Watch: how to prepare for an AML inspection, in 90 seconds
Key Components of AML/CFT Policies in UAE
Our AML/CFT policies and procedures include the crucial compliance areas and helps you to manage the financial crime risks and fulfills the UAE regulatory requirements.
Risk Assessment
We check the customer profiles, identify the business-specific risks and create a strong policy plan.
Customer Due Diligence (CDD)
We perform the ownership checks, identify verification, due diligence and document customer identification to identify the higher-risk relationships.
Transaction Monitoring and Reporting
It can identify suspicious activities, monitor transaction patterns, investigate unusual behaviour, and report concerns via applicable channels.
Record Keeping
It keeps the investigation reports, customer documents, transaction records and other crucial compliance details.
Staff Training and Awareness
Drafting the AML/CFT policies also includes conducting the employee training procedures. It helps to train the staff to handle the financial crime risks and follow the compliance practices.
Governance and Internal Controls
It manages the internal approval process, compliance officer responsibilities and review arrangements.
Sanctions Compliance
It includes transaction screening and customer document procedures, escalation processes, potential sanctions match investigations, and other targeted financial sanctions requirements.
Who Must Maintain AML/CFT Policies and Procedures in the UAE?
AML policy and procedures manual in the UAE apply to the three categories of regulated entities under the UAE's Executive Regulations.
Banks and Financial Institutions
Lenders, banks, finance companies, insurers, exchange houses, payment providers and capital market companies who are performing the regulated financial activities should maintains the proper AML/CFT policies and controls.
Designated Non-Financial Businesses and Professions (DNFBPs)
Ayanco supports AML policy for DNFBPs in the UAE. Whether you are the metals, real estate brokers, stones dealers, notaries, lawyers, independent accountants, company, trust service providers or commercial gaming operators, you must draft the policy and meet applicable AML obligations.
Virtual Asset Service Providers (VASPs)
Virtual asset service providers involves in the transfer, exchange, custody or other virtual asset activities should establish the AML/CFT controls. It can covers the customer verification, transaction monitoring and suspicious activity reporting.
Penalties for AML/CFT Non-Compliance in UAE
Failure in AML/CFT policies lead to penalties, financial risks and criminal liabilities.
| Penalty category | Potential consequences |
|---|---|
| Administrative penalties | Administrative fines of AED 50,000 to AED 5,000,000 per violation, warnings, license or registration consequences. It even restricts or banned you from running business in a specific sector. |
| DNFBP violations | Fines from AED 50,000 to AED 1,000,000 for listed violations. More penalties for repeated violations. |
| Criminal liability | Imprisonment, substantial financial penalties, and corporate dissolution for qualifying money laundering, proliferation financing offences, and terrorist financing. |
| Management accountability | Face the challenges during policy approval, high-risk relationships, and implementation of internal compliance controls. |
AML/CFT Requirements Under UAE Regulations
Avyanco guides you on all AML/CFT requirements you should meet for your business. Here are the documented AML/CFT/CPF controls you should establish under the regulatory framework.
| Regulatory framework | Key requirements |
|---|---|
| Federal Decree-Law No. 10 of 2025 | Establishes the UAE's legal framework to deal with terrorist financing, money laundering, and proliferation financing. |
| Cabinet Resolution No. 134 of 2025 | Sets out the Executive Regulations and requirements for internal policies and procedures. |
| Risk-based approach | Requires businesses to identify, determine, and understand their financial crime exposure. |
| Senior management approval | Requires documented policies and controls |
| Customer due diligence | Identify the customers and understand relevant ownership and business relationships. |
| Suspicious transaction reporting | Requires appropriate assessment and reporting of suspicious activities by applicable reporting channels. |
| Record retention | Maintains and retrieves the relevant compliance and transaction records. |
AML/CFT Policies and Procedures for Different Business Sectors in UAE
As the leading advisor, we know that the AML/CFT requirements vary by the business activities, regulatory supervision, and customer relationship. Our AML/CFT policies and procedures in the UAE is available for the following business activities
| Business sector | Key policy and procedure requirements |
|---|---|
| Financial institutions | Customer verification, sanctions screening, transaction monitoring, and suspicious activity reporting. |
| Real estate businesses | AML policy for real estate brokers in the UAE includes the due diligence, transaction risk assessment, beneficial ownership checks, and applicable sector reporting. |
| Auditors and accountants | Checking source of funds, verify customer identity and perform risk assessments. |
| Corporate service providers | Monitor the customer onboarding and business relationship. It also includes record keeping and ownership verification. |
| Dealers in precious metals and stones | Customer verification, risk assessment, applicable transaction thresholds, and sector-specific reporting. |
Applying AML/CFT Controls Across Business Activities
| Business activity | Example of an AML/CFT control |
|---|---|
| New customer onboarding | Determine the customer identity to understand the business relationship. |
| Ownership verification | Identify the relevant beneficial owners. |
| High-risk customer relationship | Implement customer due diligence policy in the UAE. |
| Unusual transaction | Check the activity and escalate internal concerns. |
| Sanctions screening alert | Check the potential matches and follow necessary freezing and reporting requirements. |
Avyanco helps you assess your compliance documentation and identify areas for improvement. Then, we provide you AML policy drafting services in the UAE as per your business activities and regulations.
How We Develop Your AML/CFT Framework in UAE
Avyanco follows an effective approach to update your AML policy in the UAE. We link the regulatory requirements with your business operations and set clear compliance responsibilities. Our approach includes the following steps.
- 1
Business Understanding
We schedule the consultation to understand your business activities, ownership structure, and regulator requirements.
- 2
Regulatory review
We review the legal obligations and supervisory expectations applicable to your UAE business.
- 3
AML gap analysis
To identify the missing or incomplete compliance controls, we review your company documentation.
- 4
Policy development
Next, we develop tailored AML policy and procedures manuals in the UAE.
- 5
Internal review
Review the draft and confirm whether it aligns to your business operations and compliance regulations.
- 6
Final documentation
Once reviewed, we submit the revised policy for management approval and implementation.
Why Choose Avyanco for AML/CFT Policies and Procedures in UAE
Avyanco addresses your financial concerns by providing AML/CFT policy and procedure services in the UAE. Here's why you can trust us
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Business Safety with AML/CFT Compliance in UAE
The AML compliance manual in Dubai ensures effective prevention of financial risks. They give your business protocols to examine and report ML/TF-related actions. Here is how it protects your business
- 40+ Specialists in Team
- 11,500+ trusted clients across the UAE
- 21+ years of senior advisory experience
- Compliance-focused documentation
Enterprise-Wide Risk Framework
- Market Risk
- Operational Risk
- Reputational Risk
- Regulatory Risk
RBA-based AML CFT Risk Framework
- Customer
- Product
- Jurisdiction
- Delivery channel
- Counterparty
Fraud Prevention and Whistleblowing
- Actions constituting fraud
- Confidentiality
- Investigation duties
- Reporting
- Legal intervention
Customer Protection and Transparent Framework
- Consumer Education and Awareness
- Business conduct and market conduct
- Responsible Financing Practices
Documents Required for AML/CFT Policy Development in UAE
Our team reviews your business information and compliance records to prepare the AML policy and align them to your organisation's structure and activities. Updating the AML/CFT Policies and procedures requires the following essential documents
- Valid trade or commercial license
- Certificate of incorporation
- Memorandum and Articles of Association
- Shareholding and ownership structure
- Ultimate Beneficial Owner information
- Organisational structure and management details
- Business activity and service information
- Existing AML/CFT policies and procedures
- Enterprise-wide risk assessment
- Customer due diligence records
- Transaction monitoring procedures
- Sanctions screening arrangements
- Compliance officer or MLRO details
- Previous audit findings or inspection reports
Why is AML/CFT compliance important in the UAE?+
AML compliance in UAE is to adhere to the laws and regulations and prevent money laundering and terrorist financing. It is important in the UAE because of the strict regulations by authorities like the UAE Central Bank and financial free zones.
Who needs AML/CFT compliance services in the UAE?+
Banks, financial institutes, auditors, real estate companies, dealers in precious metals, accountants and other companies who are at high-risk for money laundering should get the AML/CFT compliance services.
What are the penalties for non compliance to AML regulations in UAE?+
Non compliance of AML regulations can lead to fines, criminal charges, and reputational damage. UAE authorities impose the penalties to ensure the adherence.
How does Avyanco help with AML compliance?+
Our AML/CFT compliance services include handling the policy development, risk assessments, employee training and ongoing monitoring and keep your business compliant.
How often should you update the AML/CFT policies and procedures?+
We update the AML/CFL policies and procedures annually or when the major regulatory changes occur. Our team verifies that your policies remain effective and updated.
Strengthen Your AML/CFT Compliance Framework
Hire Avyanco to establish effective AML/CFT policies and procedures. Our services can manage financial crime risk, complete the goAML registration and fulfill UAE regulatory obligations. Connect with us today to discuss your documentation needs and take the leading steps ahead. Our advisors support you with
- Tailored policies for specific business activities
- Regulatory-focused documentation and control reviews
- Guidance throughout the compliance implementation
Sources: Federal Decree-Law No. 10 of 2025 · Cabinet Resolution No. 134 of 2025 · goAML · UAE Central Bank.
Verification & independence: Avyanco Business Consultancy LLC is a private firm, independent of every UAE authority, and not affiliated with any government agency. Laws, penalties and supervisory expectations are set by the authorities, vary by activity and case, and change over time. This page is general guidance, not legal, tax or accounting advice. Confirm your position with the relevant authority, or with us, before acting.