Designated by activity, not by choice or by size
AML Compliance Services
Anti-money laundering policy setup, risk assessments and goAML registration for designated non-financial businesses and professions — certain UAE sectors carry this obligation by default, regardless of company size or transaction volume.
Designation is based on activity type, not company size
Key facts
| Designated sectors | Real estate brokers and agents, dealers in precious metals and stones, corporate service providers, and others |
| Key requirements | Risk assessment, a documented AML policy, goAML registration, ongoing transaction monitoring |
| Penalty range | Administrative fines under Cabinet Resolution range AED 10,000 to AED 5,000,000 per violation; the underlying Federal Decree-Law No. 10 of 2025 sets penalties up to AED 100,000,000 for the most serious corporate breaches |
| Example tiers | AED 50,000+ for inadequate AML staff training; AED 100,000+ for inadequate new-customer risk assessment |
What this actually involves
UAE AML regulations designate specific sectors as requiring anti-money laundering compliance regardless of the individual business's size or transaction volume — real estate brokers, dealers in precious metals and stones, and corporate service providers among the most commonly designated categories. A small, two-person corporate service provider carries fundamentally the same core obligations as a much larger one; the compliance programme scales in detail, not in whether it's required at all.
The core requirements follow a consistent structure across designated sectors: a documented risk assessment identifying how the specific business could be exposed to money laundering typologies, a written AML policy reflecting that risk assessment, registration on the goAML platform for suspicious transaction reporting, and ongoing monitoring proportionate to the business's actual transaction patterns.
Businesses in adjacent but not obviously designated sectors sometimes assume they're exempt without actually checking — the designated categories are specifically defined, and a business whose activities brush up against real estate, precious metals, or corporate services provision should confirm its designation status directly rather than assume based on how the business primarily describes itself.
Is this actually relevant to you?
- You operate in a designated sector — real estate brokerage, precious metals or stones dealing, corporate service provision — regardless of your business size
- You're not certain whether your specific activity falls under AML designation and want a clear determination
- You've been designated but don't yet have a documented risk assessment, policy, or goAML registration in place
- You want your existing AML compliance programme reviewed for adequacy against current regulatory expectations
Our process, step by step
Designation confirmation
Determining definitively whether your specific activity falls under AML designation.
Risk assessment
Identifying your specific money-laundering risk exposure based on your actual client base and transaction types.
Policy & procedure setup
A working AML policy matched to your actual business, not a generic downloaded template.
goAML registration & ongoing monitoring
Registration completed and monitoring processes established proportionate to your transaction patterns.
Scope of work
AML obligations sit alongside UBO filing and are commonly reviewed as part of a compliance audit.
The assumptions that lead to accidental non-compliance
- Assuming a business is exempt from AML designation because it's small or doesn't self-identify primarily with a designated category, without checking against the specific defined activities.
- Having a generic, downloaded AML policy that doesn't actually reflect the business's real risk profile or client base.
- Registering on goAML as a one-time formality without establishing genuine ongoing transaction monitoring proportionate to actual business activity.
Related compliance services
Regulatory filings and controls kept current alongside your tax obligations.
Related guides from our team
Practical explanations of the rules behind this service, written by our chartered accountants.
Common questions
Are we a 'designated business' if we're a small corporate service provider?+
Likely yes — designation is based on activity type, not size. Worth confirming against the specific designated categories rather than assuming exemption based on company scale.
What happens if we're found non-compliant?+
Penalties can be significant, and repeated non-compliance can affect licence standing — this is treated seriously by UAE regulators across all designated sectors.
Do free zone companies in designated sectors still need AML compliance?+
Yes — AML designation applies based on activity, not jurisdiction; a free zone real estate brokerage or corporate service provider carries the same obligations as a mainland equivalent.
How often does our risk assessment need updating?+
Whenever your business activities or client base changes materially, and as a matter of good practice, reviewed periodically even without a specific trigger.
Do we need a dedicated compliance officer for AML purposes?+
Depending on your size and designation category, a specific compliance officer role may be required — worth confirming against current requirements for your specific sector.
How much are AML fines in the UAE?+
Two tiers apply. Administrative fines under Cabinet Resolution for specific compliance failures range AED 10,000 to AED 5,000,000 per violation across defined categories — inadequate staff training alone can carry a AED 50,000+ fine, inadequate customer risk assessment AED 100,000+. Separately, the 2025 AML/CFT law (Federal Decree-Law No. 10 of 2025) sets penalties of up to AED 100,000,000 for the most serious corporate breaches. These aren't hypothetical: UAE regulators have issued fines in the tens of millions against institutions for serious, repeated breaches.
Not sure if AML obligations apply to your business?
Tell us your specific activity and we'll confirm your designation status and what's required.