Compliance · AML / CFT
AML Compliance Programmes in Dubai & the UAE
If your business falls under the UAE’s AML rules, you need a programme that works in practice. We build your risk assessment, policies, due diligence and screening, train your team and prepare you for supervisor inspections.
- Risk Assessment & Policies
- CDD, EDD & Screening
- Inspection Readiness
Licensed by Dubai DET · Licence 1394564
At a glance
- Designated businesses and professions in scope
- DNFBPs
- Minimum period AML records must be kept
- 5 years
- Supervises most DNFBPs; MoJ covers lawyers and notaries
- MoE
- Receives suspicious transaction reports through goAML
- FIU
A policy on file is not a programme that works
Real estate brokers, dealers in precious metals and stones, accountants, auditors, corporate service providers and other designated businesses must comply with the UAE’s AML/CFT rules. That means a documented enterprise-wide risk assessment, policies and procedures, customer due diligence — enhanced where risk is higher — sanctions screening, a named compliance officer, staff training, records kept for at least five years and reporting to the Financial Intelligence Unit. Supervisors inspect whether all of it actually operates.
We start by confirming whether and how your activity is in scope, then build the programme around how you really do business: your customers, products, delivery channels and geographies. We write the risk assessment and policies, design due diligence and screening workflows your staff can follow, support the compliance officer, train the team and arrange an independent review of how it is working before your supervisor looks.
Key facts
- Designated businesses and professions in scope
- DNFBPs
- Minimum period AML records must be kept
- 5 years
- Supervises most DNFBPs; MoJ covers lawyers and notaries
- MoE
- Receives suspicious transaction reports through goAML
- FIU
Everything covered in AML Compliance
The concrete scope our team delivers, grouped the way we actually run your file.
Programme Design
The documents your obligations require, written for your business.
- Enterprise-wide risk assessment
- AML/CFT policy and procedures
- Customer risk-rating method
- CDD and EDD forms
- Sanctions screening procedure
- Suspicious activity escalation route
People & Operation
Making the programme run, not just exist.
- Compliance officer role and reporting lines
- goAML registration support
- Staff AML training sessions
- Screening and record-keeping set-up
- Ongoing monitoring routine
Assurance & Inspections
Evidence that stands up when the supervisor visits.
- File and screening testing
- Independent review coordination
- Inspection preparation pack
- Response to supervisor findings
- Annual programme refresh
What you gain with AML Compliance
The practical difference when the work is planned and filed properly the first time.
Scope Confirmed First
We confirm whether your licensed activity makes you a DNFBP, which supervisor applies and which obligations follow, before anything is drafted.
Risk Assessment That Fits
An enterprise-wide risk assessment built on your real customers, products, channels and countries, not a template from another sector.
Usable Policies and Procedures
Policies your staff can actually follow, with clear steps for onboarding, due diligence, escalation, reporting and record keeping.
CDD, EDD and Screening
Customer due diligence forms, risk ratings, enhanced checks for higher-risk clients and screening against the UAE local terrorist list and UN lists.
Compliance Officer Support
We help you appoint and equip a compliance officer, with a clear role, reporting lines and a monitoring routine they can maintain.
Ready for Inspection
Training logs, screening records, risk ratings and review findings organised so you can show a supervisor the programme operating day to day.
A clear process, step by step
One adviser owns your file from first call to completion, and you always know which step you are on.
- 01
Scope & Gap Review
We review your licence, activities, customer base and any existing AML documents to confirm your obligations, your supervisor and the gaps that need closing first.
- 02
Enterprise-Wide Risk Assessment
We assess money-laundering, terrorist-financing and sanctions risk across customers, products, channels and geographies, and record the ratings and reasoning your supervisor expects to see.
- 03
Policies, Procedures & Tools
We draft the AML/CFT policy and procedures, CDD and EDD forms, the risk-rating method, the screening process and the internal reporting route for suspicious activity.
- 04
Implementation & Training
We help the compliance officer put the programme into use, register on goAML where needed, and train staff on red flags, due diligence and escalation.
- 05
Review & Inspection Readiness
We test files, screening and records against your own policies, arrange an independent review, and prepare the evidence pack you would show a supervisor at inspection.
Who it’s for and what you’ll need
Have these ready and we can move quickly. If something is missing, we will tell you what the authority accepts instead.
Who must have an AML programme
- Real estate brokers and agents
- Dealers in precious metals and stones
- Accountants, auditors and corporate service providers
- Lawyers and notaries, supervised by the Ministry of Justice
- Designated businesses in DIFC or ADGM, supervised by the DFSA or FSRA
- Other businesses your supervisor treats as in scope
Information we’ll need
- Trade licence and list of licensed activities
- Description of your customers, products and payment methods
- Countries your customers and transactions involve
- Organisation chart and the proposed compliance officer
- Any existing AML policies, forms or screening tools
- Previous supervisor correspondence or inspection findings
- Sample customer files for testing
Need documents attested or translated? Our document clearing team can help.
AML Compliance questions
Straight answers to what clients ask us most. If yours is not here, ask us directly.
If your activity makes you a financial institution or a designated non-financial business or profession — for example real estate brokerage, trading in gold or precious stones, accounting, auditing or corporate services — then yes. Being in scope depends on what you actually do, not only on the licence title, so we review your activities and transactions before advising.
It is your documented assessment of how exposed the business is to money laundering, terrorist financing and sanctions breaches, looking at your customers, products and services, delivery channels and the countries involved. It drives everything else — how much due diligence you do, when you apply enhanced checks and what you monitor — so it has to be updated when the business changes.
The compliance officer should be suitably qualified and experienced, with the independence and authority to do the job, access to the records they need and a direct line to senior management. Many smaller businesses appoint an existing manager and train them. We help you define the role, document the appointment and give the officer the procedures and tools to run the programme.
At least five years under the UAE’s AML rules. That covers customer due diligence documents, transaction records, screening results and internal reports, generally counted from the end of the business relationship or the date of a one-off transaction. Records should be retrievable promptly when your supervisor or the Financial Intelligence Unit asks for them.
Typically your risk assessment, policies and procedures, a sample of customer files, screening records, training logs, the compliance officer’s reports and how suspicious activity is escalated and reported. Supervisors look for evidence that the programme operates in practice. Findings can lead to remediation demands and administrative penalties, so we test files and prepare an evidence pack beforehand.
Yes, if you are in scope of the AML rules. goAML is the Financial Intelligence Unit’s reporting platform, and businesses that must report suspicious transactions — and dealers in precious metals and stones filing cash transaction reports — need to be registered on it. Registration is one part of the programme; our goAML registration service covers it in detail.
Related services
Most clients combine these. We run them as one engagement with a single point of contact.
Let’s plan your next move
Tell us what you are planning. An adviser will come back with the route, the documents and an itemised quote — no obligation, no pressure to commit.
Visit our office
Office 44, Floor M2, BN Complex, Deira Al Muteena, Dubai, UAE
Mon – Sat, 9:00 AM – 6:00 PM (GST)
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