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.



