On 14 October 2025, Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing came into force, replacing Federal Decree-Law No. 20 of 2018. For Designated Non-Financial Businesses and Professions (DNFBPs), such as real estate brokers, dealers in precious metals and stones, accountants, auditors and corporate service providers, the message is clear: the bar for compliance and accountability has been raised.
This article summarises what changed and gives a practical checklist to help you stay ready for a Ministry of Economy inspection.
What changed in the new law?
- Proliferation financing is now part of the law's title and core framework, with standalone offences for financing the proliferation of weapons of mass destruction.
- A lower knowledge standard. A person can be held liable where they knew or should reasonably have known that funds were of criminal origin. "I did not know" is no longer a strong defence if the warning signs were there.
- Continuous monitoring is now a distinct legal duty, and due diligence extends to persons who are about to enter into a business relationship, not only existing customers.
- Virtual assets and digital systems are expressly covered: money laundering and terrorist financing offences can be committed through virtual assets, digital systems or encryption technologies.
- Stronger powers to act quickly. The head of the Financial Intelligence Unit (FIU) can suspend transactions for up to 10 working days and freeze funds for up to 30 days, extendable by the Public Prosecution.
- Asset recovery. A new framework covers confiscation and management of criminal property, and contracts made to obstruct seizure or confiscation are void.
- Higher fines for key offences, many now linked to the value of the property involved.
Existing implementing regulations and supervisory guidance remain in force until replaced, so your current obligations continue to apply.
Are you a DNFBP?
You are likely to be a DNFBP supervised by the Ministry of Economy if you are, for example:
- A real estate broker or agent involved in buying or selling property for clients.
- A dealer in precious metals or precious stones (gold, jewellery, diamonds).
- An accountant, auditor or tax agent.
- A corporate service provider (company formation, nominee or registered office services).
Lawyers and notaries are also DNFBPs but are supervised by the Ministry of Justice; free zone and financial free zone entities may have a different supervisor.
Your core obligations
- Register on goAML, the FIU's reporting platform, and keep your registration and user details up to date.
- Prepare an enterprise-wide risk assessment covering your customers, services, delivery channels and geographies, and review it at least annually.
- Adopt written AML/CFT policies and procedures approved by senior management and proportionate to your risks.
- Appoint a Compliance Officer with the authority, independence and resources to do the job.
- Apply customer due diligence (CDD): identify and verify customers and beneficial owners, understand the purpose of the relationship and the source of funds, and apply enhanced due diligence for high-risk customers and politically exposed persons (PEPs).
- Screen against sanctions lists (the UAE Local Terrorist List and UN Security Council lists) before and during the relationship, freeze without delay on a match, and report through goAML.
- Report suspicious transactions (STR) and suspicious activity (SAR) to the FIU through goAML promptly, and never tip off the customer.
- File threshold reports where required: real estate brokers file a Real Estate Activity Report (REAR) and dealers in precious metals and stones file a DPMSR for cash transactions of AED 55,000 or more, whether in a single payment or several linked payments.
- Keep records of CDD, transactions and reports for at least five years.
- Train your staff regularly and keep evidence of the training.
- Test your programme through periodic independent review.
Red flags to watch for
- A customer insists on paying large amounts in cash or splits payments to stay below AED 55,000.
- Third parties pay on behalf of the buyer with no clear relationship.
- The customer is reluctant to disclose the beneficial owner or source of funds.
- Property is bought and resold quickly at an unexplained price difference.
- Payment is offered in virtual assets without a clear, verifiable source.
- Transactions make no economic sense for the customer's profile.
Preparing for a Ministry of Economy inspection
Inspectors will usually ask to see your risk assessment, policies, goAML registration, a sample of customer files, screening evidence, reports filed, training records and the Compliance Officer's appointment. The most common findings we see are risk assessments that are generic templates, customer files without beneficial ownership evidence, and no proof that sanctions screening was done at the right time. Fixing these before an inspection is far cheaper than responding to a violation.
How we can help
KPIs Advisory Group supports DNFBPs across the UAE with goAML registration, enterprise-wide risk assessments, AML/CFT policies and KYC procedures, Compliance Officer support, mock inspections and staff training through our practical AML/CFT Compliance for DNFBPs course. Contact us for a compliance health check.
This article is for general information and reflects the law and guidance as of November 2026. It is not legal advice; obligations depend on your activity and supervisor.
