Ensuring AML Compliance in the UAE: A Deep Dive into Regulations

Raghunath T, Director


HLB HAMT - Accounting Firm in UAE

Phone:- +971 4 327 7775
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Email:- dubai@hlbhamt.com

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    In the heart of a global business hub, where economic vitality converges with regulatory challenges, the UAE grapples with the imperative of safeguarding its financial system against criminal exploitation. Marked by its presence on the Financial Action Task Force’s (FATF) increased monitoring list in 2022, the UAE has become a focal point in the battle against money laundering and counter-terrorist financing deficiencies.

    Join us as we navigate the regulatory currents, exploring the landscape of AML compliance in the UAE and uncovering the strategies employed to ensure financial integrity in this dynamic corner of the world.


    The Central Bank of the UAE (CBUAE) serves as the primary financial regulator in the country, overseeing Anti-Money Laundering and Combatting the Financing of Terrorism (AML/CFT) supervision through its specialized department, the Anti-Money Laundering and Combatting the Financing of Terrorism Supervision Department (AMLD). AMLD focuses on regulatory compliance and collaborates with law enforcement authorities and the UAE’s Financial Intelligence Unit (FIU).

    The AMLD operates with three main objectives:

    • Evaluate licensed financial institutions (LFIs) in the UAE.
    • Ensure adherence to the regulatory and legal framework for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) in the UAE.
    • Identify AML/CFT threats, emerging risks, and weaknesses in the UAE’s financial system.


    The principal components of the UAE’s Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) legislation are outlined in two key documents:

    • Legislative measures, namely Federal Decree-Law No. (20) of 2018 addressing Anti-Money Laundering, Combating the Financing of Terrorism, and Financing of Illegal Organizations.
    • The regulatory framework includes Cabinet Decision No. (10) of 2019, outlining the Implementing Regulation for Decree-Law No. (20) of 2018 on Anti-Money Laundering, Combating the Financing of Terrorism, and Illegal Organizations.

    Referred to as the AML/CFT Law and the AML/CFT Decision respectively, these articles collectively mandate that businesses in the UAE establish and execute a risk-based AML/CFT program.

    This program encompasses elements such as Know Your Customer (KYC) checks, risk screening solutions, reporting and record-keeping processes, and effective compliance governance. Additionally, the regulations stipulate the appointment of an AML Compliance Officer responsible for overseeing the compliance solution within their organization.

    Complying with UAE AML Regulations: Key Steps

    Following FATF guidance, firms in the UAE are required to adopt a risk-based AML/CFT approach, involving the following measures:

    Customer Identification:

    • Conduct customer due diligence (CDD) to establish and verify customer identity.
    • Determine ultimate beneficial ownership (UBO) to prevent the use of shell entities for identity concealment.

     Enhanced Due Diligence (EDD):

    • Implement EDD for customers deemed high AML risk, involving more thorough scrutiny, possibly requiring official document copies or third-party audits. 

    Transaction Screening:

    • Continuously screen customer transactions for AML risk, particularly those involving high-risk counterparts or jurisdictions.

    Sanctions and Watchlists:

    • Mitigate sanctions risk by implementing effective screening for designated customers on international sanctions lists. Identify politically exposed persons (PEPs) through screening against PEP lists, given the heightened risk in the UAE.

    HLB HAMT For Your AML/CFT Requirements

    Ensuring AML compliance in the UAE requires a multifaceted approach involving robust regulations, effective enforcement, and a commitment to ongoing education and technological advancements.

    HLB HAMT, with its team of AML experts, stands ready to assist you in ensuring robust compliance with the UAE’s AML regulations. From comprehensive risk assessments to implementing effective AML/CFT solutions, our experts are equipped to guide your organization through the complexities of AML compliance.

    Contact HLB HAMT today for expert assistance!



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