Corporate & compliance
AML compliance in the UAE: a guide for businesses
Who the UAE anti-money laundering rules apply to, and the core controls regulated businesses are expected to maintain.
The UAE has built a comprehensive framework to combat money laundering and the financing of terrorism and proliferation, aligned with the standards of the Financial Action Task Force. For regulated businesses, compliance is an everyday operational duty, not a one-off exercise.
The framework
The core instrument is now Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing. It came into force on 14 October 2025, repealing Federal Decree-Law No. 20 of 2018. Its Executive Regulations are Cabinet Resolution No. 134 of 2025. Regulations and circulars issued under the previous law remain effective, to the extent they do not conflict, until they are replaced. The framework is supported by guidance from the supervisory authorities.
Who it applies to
The rules apply to financial institutions, virtual asset service providers, and designated non-financial businesses and professions. These include real estate brokers, dealers in precious metals and stones, auditors, corporate service providers, and lawyers when carrying out specified activities.
Core obligations
- Customer due diligence: identify and verify customers and beneficial owners, with enhanced measures for higher-risk relationships.
- Risk assessment: identify, document and regularly update the risks linked to products, services, customers and geography.
- Record keeping: keep identification and transaction records for the period the law requires.
- Suspicious transaction reporting: report suspicious transactions to the Financial Intelligence Unit without delay, whatever the amount.
- Training and internal controls: train staff and maintain policies, procedures and a compliance function proportionate to the business.
What this means for law firms
Under Cabinet Resolution No. 134 of 2025 (Article 3), lawyers, notaries and other independent legal professionals fall within the framework when they prepare, conduct or execute financial transactions for clients in connection with: buying and selling real estate; managing client funds; managing bank, savings or securities accounts; organising contributions to establish, operate or manage companies; and establishing, operating or managing legal persons or legal arrangements, or buying and selling commercial entities.
When a firm carries out these activities, the obligations above apply to that work. In practice this means client and beneficial-owner checks before acting, a documented risk assessment, records kept for the required period, and internal reporting to a compliance officer, who files any suspicious transaction report with the Financial Intelligence Unit through the goAML system. A firm that cannot complete due diligence should not begin or continue the relationship or transaction. Clients must not be told that a report has been made or is being considered.
Legal professional secrecy is preserved. Under Article 18 of Federal Decree-Law No. 10 of 2025 and its Executive Regulations, the reporting duty does not apply to information obtained while assessing a client's legal position, representing a client in court, arbitration or mediation, or advising on starting or avoiding proceedings, or in other circumstances covered by professional secrecy. The Ministry of Justice supervises law firms and legal consultancy offices and has issued guidance for them.
Whether a particular matter falls within these activities depends on the facts. Information obtained in litigation and advisory work is generally covered by the professional-secrecy exemption; transactional work for clients may fall within scope.
AML legislation and guidance are updated regularly. Check the current position for your sector before relying on this summary. General information only, not legal advice.
