Find out whether your business is a designated non-financial business under UAE anti-money laundering law, and get registered on goAML. PROXPAT prepares the registration documents and keeps your licence file in order.
Page last updated: . Requirements, government fees and processing times are set by the relevant UAE authority and can change.
AML Compliance and goAML Registration for UAE Businesses
Some non-financial businesses in the UAE carry anti-money laundering duties similar to those of banks. The law calls them Designated Non-Financial Businesses and Professions (DNFBPs). They include real estate brokers, dealers in precious metals and stones, independent accountants and company service providers.
DNFBPs must register on goAML, the platform the UAE Financial Intelligence Unit uses to receive suspicious transaction reports. The Ministry of Economy and Tourism warns that failing to register may lead to severe penalties. This page explains who is covered and what the current rules require.
Please note: this page summarises official sources and is not legal advice. Confirm your obligations with your supervisory authority or a qualified AML adviser.
The Current Legal Framework
| Instrument | Role |
|---|---|
| Federal Decree-Law No. 10 of 2025 | The law on anti-money laundering and combating the financing of terrorism and proliferation financing |
| Cabinet Resolution No. 134 of 2025 | The executive regulations of Decree-Law No. 10 of 2025, issued on 29 October 2025 and effective from 14 December 2025, according to the UAE Legislation portal |
| Financial Intelligence Unit (FIU) | An independent unit within the Central Bank that exclusively receives suspicious transaction reports (Decree-Law No. 10 of 2025, Article 11) |
Decree-Law No. 10 of 2025 repealed Federal Decree-Law No. 20 of 2018 (Article 41). Regulations and circulars issued under the old law stay in force where they do not conflict with the new law, until they are replaced. Some guidance, including the Ministry's goAML page, still cites the 2018 law, so make sure your internal policies refer to the current instruments.
Who Is a DNFBP?
| Category | When the rules apply |
|---|---|
| Real estate brokers and agents | When concluding purchase or sale transactions or settlements for customers |
| Dealers in precious metals and stones | For a single cash transaction, or linked transactions, of AED 55,000 or more |
| Lawyers, notaries, other independent legal professionals and independent accountants | When preparing or carrying out transactions for customers involving buying or selling real estate, managing client funds or accounts, organising contributions to companies, or creating, running, buying or selling legal persons or arrangements |
| Company and trust service providers | When acting as an incorporation agent, acting or arranging for someone to act as a director, secretary or partner, providing a registered office or business address, acting as a trustee, or acting or arranging a nominee shareholder |
| Commercial gaming operators | For a single financial transaction, or linked transactions, of AED 11,000 or more |
The supervisory authority can add further businesses or professions by resolution. The Ministry of Economy and Tourism's online self-check covers real estate firms, auditing and accounting firms, precious metals and stones dealers, and company service providers. See real estate brokerage licence.
Registering on goAML
The Ministry of Economy and Tourism lists these steps and documents for DNFBP registration:
Step 1: Register in the goAML protection system (SACM) and obtain a username.
Step 2: Install the Google Authenticator app, which generates the SACM password that changes every minute.
Step 3: Complete the goAML registration with the documents below.
| Document | Notes |
|---|---|
| Authorisation letter from the institution you represent | Issued by the business |
| Copies of passport, residence visa and Emirates ID | For the person registering |
| Copy of the commercial trade licence | For companies |
The Ministry also publishes a goAML system registration guide and a guide to changing the registered MLRO (money laundering reporting officer).
Core Obligations Once Registered
| Obligation | What the rules require | Source |
|---|---|---|
| Risk assessment | Identify and assess money laundering risks, keep the risk assessment study and provide it to the supervisory authority on request | Decree-Law No. 10 of 2025, Article 19 |
| Customer due diligence | Identify and verify customers and beneficial owners when a business relationship starts, when a crime is suspected, or when earlier identification data is doubtful, with ongoing monitoring | Resolution No. 134 of 2025, Articles 7 and 8 |
| Internal policies | Policies approved by senior management covering due diligence, suspicious transaction reporting, staff screening, training and an independent audit function | Resolution No. 134 of 2025, Article 21 |
| Compliance officer | A compliance officer at management level, with independence and appropriate competence and experience, who monitors transactions and decides whether to report to the FIU | Resolution No. 134 of 2025, Article 22 |
| Suspicious transaction reports | Report immediately and without delay to the FIU through its electronic system, whatever the amount, and answer FIU requests promptly | Resolution No. 134 of 2025, Article 18 |
| Record keeping | Keep transaction and due diligence records for at least five years and make them available to authorities on request | Resolution No. 134 of 2025, Article 25 |
Supervisory authorities keep a list of the compliance officers of the entities they supervise and can require their prior approval before a compliance officer is appointed.
Record Keeping Details
- Transaction records: at least five years from completing the transaction or ending the business relationship.
- Due diligence files: customer files, correspondence, identity document copies and suspicious transaction reports are kept for at least five years from the latest of the end of the relationship, an occasional transaction, a supervisory inspection, an investigation or a final court judgment.
- Dissolved companies: those responsible for a company's management or liquidation keep its beneficial ownership records for at least five years after dissolution (Article 40).
For tax and company law retention periods, see accounting and record keeping.
Penalties for Not Registering
The Ministry of Economy and Tourism states that failing to register on goAML may lead to severe penalties. On 21 August 2023 it announced suspending the operations of 50 DNFBP establishments for three months for failing to register, and warned of stronger penalties if they did not comply within the suspension period.
In the same announcement, the Ministry said it had imposed fines of about AED 76.9 million on 225 DNFBP companies between the start of 2023 and that date.
Setting Up a Business That Is a DNFBP
- Check at the licensing stage whether your activity falls under Article 3 of Cabinet Resolution No. 134 of 2025.
- Plan goAML registration before you start serving customers.
- Choose the compliance officer early, since supervisors can require prior approval of the appointment.
- Write risk assessment and due diligence procedures before onboarding your first customer.
- Set up a five-year record archive from day one.
See business activity consultation. Virtual asset service providers have their own AML duties; see VARA crypto licence.
How PROXPAT Helps
DNFBP activity check at licensing
goAML registration document preparation
Authorisation letter and ID copies
Trade licence issuance and amendments
Compliance officer change paperwork
Record archive organisation
Coordination with AML advisers
Licence renewals without compliance gaps
Frequently Asked Questions
Stay licensed and compliant.
Explore connected PROXPAT services that support the same client journey.
The licence is the start of the government work, not the end of it
Once the trade licence is issued, the sequence that actually lets you operate begins: the establishment card, the MOHRE and immigration files, your employee quota, then employee visas and work permits. After that it repeats every year — renewals, cancellations when people leave, and licence renewal and amendments.
Companies that would rather not build that function in-house put it on a monthly PRO retainer from AED 700, or use it per transaction. Government fees stay separate and itemised either way.
The first six months after incorporation
- Establishment card issued through immigration
- MOHRE file opened and e-signature completed
- Employee quota checked before hiring
- Offer letters, work permits and entry permits
- Medical, Emirates ID and visa stamping
- Corporate tax and VAT registration where they apply
More in Licences and Compliance
Get Registered on goAML
PROXPAT checks whether your activities make you a DNFBP, prepares the goAML registration documents and keeps your licence and compliance officer details up to date.