The regulatory landscape in the United Arab Emirates (UAE) continues to evolve to align with international best practices in Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF). Designated Non-Financial Businesses and Professions (DNFBPs) play a critical role in this ecosystem. As such, understanding and meeting compliance requirements is not just a legal obligation for DNFBPs in the UAE, but a vital step toward maintaining operational legitimacy and protecting the economy from financial crime.

Who are DNFBPs?

In the context of the UAE, DNFBPs include businesses and professions that, while not part of the formal financial sector, are exposed to money laundering and terrorist financing risks due to the nature of their services. These include:

• Real estate agents and brokers
• Dealers in precious metals and stones
• Auditors and accounting firms
• Corporate service providers
• Lawyers and legal consultants (when involved in certain financial transactions)
• Trust and company service providers

Each of these sectors is governed under the Cabinet Decision No. (10) of 2019 concerning the implementing regulation of Federal Decree-Law No. (20) of 2018 on AML and CTF.

Key Compliance Obligations for DNFBPs

1. Registration with the Relevant Authority

All DNFBPs must register with the Financial Intelligence Unit (goAML) and the Committee for Commodities Subject to Import and Export Control (automatic reporting system for sanctions lists). These systems are crucial for monitoring suspicious activities and ensuring transparency.

2. Risk-Based Approach (RBA)

DNFBPs are required to adopt a Risk-Based Approach to compliance, which involves:

• Conducting a risk assessment specific to their business
• Identifying and categorizing clients according to their risk level (low, medium, high)
• Implementing proportionate measures based on the risk level

This approach ensures resources are efficiently used to mitigate higher risks while maintaining adequate oversight across all operations.

3. Customer Due Diligence (CDD)

DNFBPs must carry out Customer Due Diligence before establishing a business relationship or conducting occasional transactions above designated thresholds. This includes:

• Identifying and verifying the identity of clients
• Understanding the nature and purpose of the business relationship
• Identifying the beneficial owner(s)
• Monitoring the business relationship on an ongoing basis

Enhanced Due Diligence (EDD) must be applied in high-risk cases, such as dealing with politically exposed persons (PEPs) or high-risk jurisdictions.

4. Record Keeping

DNFBPs are mandated to retain all records related to transactions, CDD, and internal/external reports for a minimum of five years. These records must be easily retrievable and made available to authorities upon request.

5. Reporting Obligations

DNFBPs must report:

• Suspicious Transaction Reports (STRs) to the FIU through goAML
• Threshold Transactions involving cash over AED 55,000 for dealers in precious metals and stones
• Any dealings with individuals/entities on UN or UAE sanctions lists

Failure to report suspicious activities can result in penalties, business license suspension, or criminal proceedings.

6. Internal Policies, Procedures & Controls

Firms must establish documented internal policies that govern:

• AML/CTF compliance
• Employee screening and hiring
• Staff training and awareness programs
• Escalation and reporting protocols

The goal is to cultivate a compliance culture embedded in the day-to-day operations of the business.

7. Appointment of a Compliance Officer

It is a regulatory requirement for DNFBPs to appoint a dedicated Compliance Officer or MLRO (Money Laundering Reporting Officer). This individual must be:

• Competent and qualified
• Responsible for ensuring AML/CTF compliance
• Liaison between the organization and the supervisory authorities

This role is pivotal in ensuring accountability and responsiveness in dealing with compliance matters.

Enforcement & Penalties

The UAE has adopted a firm stance on non-compliance. Penalties for DNFBPs include:

• Fines up to AED 5 million
• Suspension or cancellation of business licenses
• Inclusion in public blacklists
• Criminal prosecution in severe cases

To enforce these regulations, the Ministry of Economy acts as the supervisory authority for most DNFBPs, conducting periodic inspections and issuing fines for violations.

Recent Developments in 2025

With the UAE’s continued efforts to exit the FATF grey list, compliance enforcement has tightened significantly in 2024 and 2025. DNFBPs are now under increased scrutiny, and regulators have introduced:

• Stricter inspection protocols
• Real-time monitoring of STR submissions
• Mandatory compliance audits for high-risk firms

Firms that lag in implementing robust compliance programs are facing swift corrective actions.

Final Thoughts

Compliance for DNFBPs in the UAE is not just a checkbox exercise. It reflects a company’s commitment to ethical business practices and international standards. Given the increasing regulatory pressure and rising awareness of financial crime risks, it is essential for all DNFBPs to proactively build and maintain a strong compliance framework.

Whether you’re a real estate broker closing high-value deals or a jeweler handling cash transactions, aligning your business with the UAE’s AML/CTF requirements is no longer optional—it’s a strategic necessity.

If you’re unsure about your current compliance posture or need help implementing a tailored AML/CTF program, consulting experts like Privis Management Consultants can ensure you’re on the right track.