1
Register on the UAE AML Reporting Platform
You must register your company on the UAE Financial Intelligence Unit's goAML portal (via SACM) and provide business details and your appointed AML officer. This system is used to report suspicious transactions and activities.
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2
Appoint an AML Compliance Officer (MLRO)
A qualified AML Compliance Officer or Money Laundering Reporting Officer must be designated to oversee your AML programme, monitor controls, file reports, train staff and act as a liaison with authorities.
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3
Conduct an Enterprise-Wide AML Risk Assessment
You must prepare a formal risk assessment report evaluating the money-laundering risks associated with your services, customers, products, delivery channels and jurisdictions, and document how you will mitigate those risks.
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4
Implement Customer Due Diligence (CDD) & KYC
You need robust Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures that cover: verifying identity and addresses of customers and beneficial owners; understanding the nature and purpose of business relationships; Enhanced Due Diligence (EDD) for high-risk or politically exposed customers. All checks must be documented and completed before transaction execution.
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5
Sanctions Screening & Ongoing Monitoring
Customers, counterparties and transactions must be continuously screened against sanctions lists (UAE national, UN, OFAC, etc.), and transactions should be monitored for unusual patterns.
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6
Suspicious Transaction Reporting (STR/SAR)
If you identify unusual or suspicious activity that could indicate money laundering, you must file a Suspicious Transaction Report (STR) with the FIU through the goAML portal within required timelines (typically within 3–5 working days of identification).
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7
AML Policies & Internal Controls
Your business must establish and maintain documented internal policies, procedures and controls covering: customer acceptance policy; risk management procedures; KYC/CDD/EDD processes; transaction monitoring and escalation rules; reporting mechanisms. These should be approved by senior management and reviewed regularly.
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8
Record Keeping & Documentation
Maintain detailed records of all CDD, transactions, risk assessments, training logs, screening results and STRs for a minimum of five years (often longer as best practice) so you can demonstrate compliance to regulators.
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9
Compliance With Latest Law & Regulatory Inspections
Under updated laws (e.g., Federal Decree-Law no. 10 of 2025), compliance is mandatory for regulated entities (banks, DNFBPs such as accountants, lawyers, real estate agents, VASPs, etc.). Authorities may conduct inspections, and non-compliance can lead to significant fines, license suspension or legal action.
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