The UAE’s 2025 anti-money laundering reforms provide the legislative context for designated non-financial businesses and professions (DNFBPs) reviewing their compliance programmes. Business-wide risk assessments, customer due diligence, beneficial ownership records, sanctions screening and reporting remain central areas to examine.
This article revisits the 2025 changes and their practical implications for DNFBPs’ ongoing compliance.
The 2025 Legislative Changes
Federal Decree-Law No. 10 of 2025 entered into force on 14 October 2025, replacing Federal Decree-Law No. 20 of 2018. Cabinet Resolution No. 134 of 2025 sets out the supporting executive regulations for combating money laundering, terrorist financing and proliferation financing.
These measures date from 2025. Subsequent industry commentary discusses their implementation and does not, by itself, introduce new obligations or deadlines.
Reviewing DNFBP Compliance Controls
DNFBPs reviewing their AML programmes should examine whether their documentation reflects how controls operate in practice. Relevant areas include:
- A documented and regularly reviewed business-wide risk assessment.
- Customer identification, due diligence and beneficial ownership records.
- Sanctions screening procedures, alert reviews and documented decisions.
- goAML registration and applicable reporting records.
- Staff training records and compliance officer responsibilities.
A documented ML/TF risk assessment helps businesses identify their exposure and prioritise appropriate controls.
Understanding goAML Reporting Obligations
Reporting through the UAE Financial Intelligence Unit’s goAML platform remains an important compliance consideration. Alongside suspicious transaction reporting, certain activities involving precious metals and stones or real estate may carry separate reporting requirements.
Businesses should check the applicable reporting triggers, conditions and instructions for their sector rather than assume that the same requirements apply to every DNFBP.
Practical Steps for Businesses
DNFBPs should review their policies and procedures against the applicable legislation and instructions from their supervising authority. After identifying gaps, corrective action must address the written process and the daily implementation.
An AML gap assessment helps businesses idetinfy weaknesses, prioritise remediation and document any changes made.
The primary focus is to maintain effective controls under the framework introduced in 2025. Businesses must distinguish commentary revisiting those reforms from official notices announcing subsequent changes or deadlines.
