AML Policy and goAML Registration

If you are a DNFBP, an AML policy and an active goAML registration are legal obligations. The ministry has suspended firms for three months over the registration alone.

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Four kinds of business have carried anti money laundering obligations in the UAE for years, being real estate firms, auditors and accountants, dealers in precious metals and stones, and trust or company service providers, and commercial gaming operators have since been added. If you are one of them you are a designated non financial business or profession, a DNFBP, supervised by the Ministry of Economy and Tourism. You are required to hold a written AML policy, assess your risk, run customer due diligence, keep records, appoint a compliance officer and register on goAML and keep that registration active. The fine is not the sharpest risk. In a published announcement the ministry suspended fifty DNFBP establishments for three months purely for failing to register on goAML, with the suspension in force until they registered. Three months of suspended trading costs most small firms more than any fine on the schedule.

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Key Features

Status established first, because a firm that is not a DNFBP does not need any of this, and a firm that is has been obliged since before it asked the question
A written AML policy built to what the supervisor expects, covering risk assessment, customer due diligence, ongoing monitoring, and the reporting of suspicious transactions
goAML registration completed and kept active, with the compliance officer registered as the system user, which is how the ministry guidance requires it to be held
Record keeping set up to the statutory period, since the obligation is to hold complete records of transactions and to produce them on request
You supply your trade licence, your activity, your customer types and your transaction volumes, which is what sets the risk assessment the policy is built on

Benefits for Your Business

Registered and active on goAML, which is the single point the ministry has suspended firms over.
A policy that reflects your actual business rather than a downloaded template with another name on it.
A compliance officer appointed and registered properly, rather than named on paper only.
An honest answer on whether you are a DNFBP at all, which for many firms is the end of the matter.

General information, not legal or compliance advice. UAE anti money laundering obligations sit in Federal Decree-Law 10 of 2025 and the administrative penalty schedule annexed to Cabinet Resolution 71 of 2024, with DNFBPs supervised by the Ministry of Economy and Tourism. DIFC and ADGM operate their own regimes under their own regulators and are outside this service. Requirements were read on 16 September 2026 and change.

Who must comply with AML rules in the UAE?

If your business is one of these, it is a DNFBP (designated non financial business or profession) supervised by the Ministry of Economy and Tourism:

Business	Typical example
Real estate	Brokers and agents
Precious metals and stones	Gold and jewellery dealers
Auditors and accountants	Audit and bookkeeping firms
Company and trust service providers	Business setup and corporate services firms
Commercial gaming	Licensed gaming operators

UAE AML compliance checklist

Register on goAML and keep the registration active.
Appoint a compliance officer and register them as the goAML user.
Write an AML policy based on your own risk assessment.
Run customer due diligence, with enhanced checks for higher risk customers.
Report suspicious transactions through goAML.
Keep records for the statutory period and produce them on request.
Train staff and review the policy regularly.

Your company must also keep an accurate UBO register, which banks and the ministry both ask for.

Frequently Asked Questions

Who needs AML compliance in the UAE?

Designated non financial businesses and professions: real estate firms, dealers in precious metals and stones, auditors and accountants, company and trust service providers, and commercial gaming operators, as well as financial institutions.

What is goAML?

The UAE Financial Intelligence Unit's system for registering reporting entities and filing suspicious transaction reports. DNFBPs must register and keep their registration active.

What happens if a DNFBP does not register on goAML?

Fines apply, and the ministry has suspended firms: in one published case it suspended fifty establishments for three months for failing to register.

Do I need a compliance officer for AML in the UAE?

Yes. A DNFBP must appoint a compliance officer, who is also registered as the goAML user.

Which law covers AML in the UAE?

Federal Decree-Law 10 of 2025, with administrative penalties in the schedule to Cabinet Resolution 71 of 2024. DIFC and ADGM have their own regimes.