AML/CFT Compliance Services in Dubai, UAE

AML/CFT Compliance

Ensuring compliance with Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations in Dubai is vital to protect your business and maintain the UAE’s financial integrity. At HLB HAMT, we make compliance straightforward with our specialized AML/CFT consulting services, tailored to meet your unique requirements. Backed by over 25 years of experience and a dedicated team of AML experts, we have successfully assisted more than 100 DNFBPs in achieving full alignment with UAE AML regulations. Our services cover the development of customized AML/CFT policies and procedures, support with goAML registration, and ongoing advisory services to ensure your business remains compliant and well-prepared in an evolving regulatory environment.

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HLB HAMT’s AML/CFT services

Gap Analysis

We evaluate your current AML framework to ensure it aligns with UAE regulatory requirements.

Tailored AML/CFT Policies

We develop AML/CFT policies customized to your business risks and operational requirements

CDD, EDD & Risk Assessment

We develop comprehensive due diligence and risk management processes tailored to your sector

CDD Tool Implementation

We assist in implementing Screening and risk assessment tools to ensure consistent and reliable compliance checks.

Staff Training Workshops

We provide specialized AML training designed for Real Estate, DPMS, Corporate Service providers & Accounting professionals.

goAML Registration Support

We offer end-to-end support for goAML portal setup and FIU onboarding.

Outsourced Compliance Officer / MLRO

We act as your external/outsourced MLRO or Compliance Officer to ensure full compliance

Ongoing Advisory Support

We offer continuous support to maintain and strengthen your AML framework

Why Choose Us

Why Choose HLB HAMT for AML/CFT Compliance in the UAE?

Why Choose HLB HAMT

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The UAE has established a robust Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) framework to protect its financial system and align with global standards set by the Financial Action Task Force (FATF). Key regulations include:

Federal Law No. 20 of 2018 on Anti-Money Laundering

This foundational law outlines key AML/CFT obligations in the UAE. It:

  • Defines and Criminalization of ML and Terrorist Financing (TF) Mandates
  • Obligations on Financial Institutions and DNFBPs: Customer Due Diligence (CDD) and Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit (FIU)
  • Grants supervisory authorities’ powers to enforce compliance
  • Supports international cooperation on AML/CFT
  • Penalties and Enforcement for Non-compliance with the law.

Cabinet Decision No. 10 of 2019

This decision provides the implementing regulations for AML compliance. It:

  • Introduces a Risk-Based Approach (RBA) to managing ML/TF risks
  • Requires Enhanced Due Diligence (EDD) and ongoing monitoring
  • Mandates a 5-year record retention period
  • Requirement for Compliance officer
  • Strengthened Reporting and Record-Keeping

2024 AML Law Amendments: What Your Business Needs to Know

its Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and proliferation financing framework. These updates, aligned with the 2024–2027 National Strategy for AML/CFT, prepare the UAE for the 2025–2027 FATF Mutual Evaluation and reinforce its commitment to global financial integrity.

On August 11, 2024, the UAE introduced Federal Decree-Law No. 7/2024, amending Federal Decree-Law No. 20/2018 to strengthen:

  • National Committee for AML/CFT: Established to coordinate national-level compliance efforts and guide risk-based implementation.
  • Supreme Committee: Responsible for overseeing AML/CFT policies and evaluating the effectiveness of enforcement measures.
Implications on Businesses: 
These bodies will bring uniformity in how AML obligations are interpreted and enforced, leading to more consistent—and potentially stricter—compliance expectations across all sector
  • The amendments promote closer coordination between regulators, government authorities, and reporting entities to improve enforcement and monitoring.
Implications on Businesses: 
Companies must align with a more structured AML framework, with greater emphasis on real-time implementation and follow-through.
  • The National Committee will lead the development of the UAE’s Mutual Evaluation to assess alignment with FATF global AML/CFT standards.
Implications on Businesses: 
Expect more rigorous inspections, enhanced scrutiny of documentation, and increased pressure to demonstrate the effectiveness of your AML program in practice.

Administrative Penalties & Fine Matrix

Non-compliance with UAE Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations can lead to severe penalties, including hefty fines and reputational damage.

Fine Amount (AED) Applicable Violations
1,000,000 or more
  • Dealing with sanctioned individuals/entities without proper due diligence
  • Engaging with unauthorized banks
  • Opening or maintaining bank accounts under false names
200,000 or more
  • Failure to apply Enhanced Due Diligence (EDD) for high-risk customers
  • Not reporting STRs to the FIU
  • Non-compliance with FIU requests for additional information
  • Tipping off clients or third parties about AML investigations
  • Non-implementation of measures for high-risk jurisdictions
100,000 or more
  • Inadequate client due diligence (CDD)
  • Failure to verify identity of customers, UBOs, or PEPs
  • Delayed STR reporting
  • Poor record-keeping of financial transactions
50,000 or more
  • No AML training for staff
  • Denial of access to records by competent authorities
  • Incomplete or irregular record maintenance (less than 5 years)
  • No appointment of AML Compliance Officer (MLRO)
  • Lack of customer monitoring procedures
  • Failure to implement simplified due diligence for low-risk clients
  • Absence of internal AML policies and risk mitigation procedures

Recent Enforcement Trends:

In a clear demonstration of its zero-tolerance stance on AML violations, the Central Bank of the UAE (CBUAE) imposed over AED 339 million in penalties in 2025 alone.

This sharp increase in enforcement sends a strong signal to businesses: implementing a robust AML/CFT program is no longer optional — it is essential.

Specialized AML Support for DNFBPs (Real Estate & Precious Metals,CSP,Law firms & Accountants)

To ensure complete AML compliance among Designated Non-Financial Businesses and Professions (DNFBPs), the Ministry of Economy mandates that companies fulfill specific risk assessment requirements. It is crucial for companies to establish a robust AML/CFT (Anti Money Laundering/Combating the Financing of Terrorism) framework, which includes the following essential components:

Failure to comply with these requirements could result in legal accountability, financial fines, or administrative penalties. To mitigate these risks, HLB HAMT offers comprehensive AML compliance services Dubai specifically designed for DNFBPs, ensuring that companies not only meet regulatory standards but also foster a culture of compliance within their operations.

Recent AML Case Studies

01

Real Estate Brokerage Fine (2023)

Issue: AED 1.8M fine for failure to register, missing STRs, no Compliance Officer, and lack of AML policies.
HLB HAMT Solution:
 Conducted detailed gap analysis
 Developed and implemented tailored AML policies
 Guided full remediation in 90 days

Outcome: Restored compliance and improved regulatory standing

02

Gold Trader Sanctioned (2022)

Issue: Sanctioned for failing CDD — missing UBO checks, no source of funds verification, and no sanctions screening.
HLB HAMT Solution:
 Implemented comprehensive CDD procedures
 Strengthened internal AML controls

Outcome: Enhanced AML compliance framework and reduced enforcement risk

Ready to Simplify Your AML Compliance Journey?

Get expert guidance from UAE’s leading AML/CFT compliance specialists

Frequently Asked Questions

What is the CDD threshold for occasional transactions in the UAE?

Customer Due Diligence (CDD) is required when occasional transactions equal to or above AED 55,000 are conducte

Under UAE AML/CFT laws, the following Designated Non-Financial Businesses and Professions (DNFBPs) fall under regulatory supervision:
• Real Estate: Brokers and developers
• DPMS: Dealers in gold, diamonds, and precious materials
• Accountants
• Trust and Company Service Providers
• Law firms

EDD is required in cases involving high-risk customers, including:
• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Cases involving complex or unusually large transactions
• When there is insufficient information on the source of funds or wealth
EDD involves collecting additional documents, verifying source of funds, and obtaining senior management approval before onboarding.

AML-related records must be maintained for a minimum of five years.
This includes customer identification, screening results, and any STR documentation, in line with regulatory expectations.

AML/CFT compliance is essential in the UAE as it safeguards the financial system from being exploited for unlawful activities, including money laundering and financing terrorism. Failure to comply with these regulations can lead to heavy fines, legal repercussions, and significant reputational harm.

AML/CFT regulations apply to a wide range of businesses, including banks, insurance companies, financial institutions, real estate brokers, auditors, lawyers, and any entities dealing with high-value goods or financial transactions. These businesses are required to establish robust AML/CFT policies and procedures to prevent misuse.

Businesses should conduct AML/CFT training at least annually to ensure that employees are up-to-date with the latest regulatory requirements and best practices. Training should also be provided whenever there are significant updates to AML/CFT laws or internal policies.

Businesses can protect themselves by implementing strong AML/CFT policies, conducting regular risk assessments, performing thorough customer due diligence (CDD), and monitoring transactions for suspicious activities. Regular training for staff on compliance procedures also plays a crucial role in prevention.

Non-compliance with AML regulations in the UAE can lead to severe penalties, including hefty fines, legal actions, suspension of business licenses, and reputational damage. It can also result in a loss of trust from clients and business partners.

The Ministry of Economy requires that Designated Non-Financial Businesses and Professions (DNFBPs) fulfil specific risk assessment requirements to ensure AML compliance. These requirements include having a comprehensive AML/CFT policy, submitting MLRO reports, conducting an Enterprise-Wide Risk Assessment (EWRA), performing a gap analysis, executing an AML independent audit, and developing a Compliance Annual Plan.

DNFBPs that fail to comply with the Ministry of Economy’s AML risk assessment requirements may face serious consequences, including legal accountability, financial fines, and administrative penalties. To avoid these risks, it is essential for companies to implement the necessary AML/CFT measures and maintain compliance with the required frameworks.

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