AML compliance guides for UAE businesses.

AML/CFT obligations apply to financial institutions and to DNFBPs — Designated Non-Financial Businesses and Professions — including real estate agents and brokers, dealers in precious metals and stones, corporate service providers, auditors and certain others. Businesses in scope must register on goAML and implement a compliance programme.

goAML is the UAE Financial Intelligence Unit's platform for AML registration and reporting. Businesses in scope must register, then submit suspicious-transaction and other required reports through it. Registration is typically the first formal AML step for a DNFBP.

Money laundering is conventionally described in three stages: placement, where illicit cash first enters the financial system; layering, where it is moved through transactions, entities or borders to obscure its origin; and integration, where it re-emerges as apparently legitimate funds — often through property, trade or business investment. UAE DNFBPs are expected to understand these stages because their sectors — real estate, precious metals, corporate services — are common vehicles for placement and integration, which is exactly what customer due diligence and transaction monitoring are designed to catch.

A programme generally includes a business risk assessment, customer due diligence and KYC procedures, sanctions and PEP screening, ongoing monitoring, staff training, record-keeping and an appointed compliance officer (MLRO) responsible for reporting. It should be documented and applied in practice, not just on paper.