AMCA’s 2026 AML Guide gives a clear overview of the latest AML requirements for UAE businesses, including key laws, checklists, penalties, and ways to stay compliant.
The UAE has revised its laws to meet the international standards of AML. Federal Decree-Law No. 10 of 2025 annulled the 2018 law and has come out with more stringent enforcement, higher fines, and more compliance liabilities across all businesses and notably financial institutions, DNFBPs, and VASPs.
These changes further reveal how the UAE is committed to meeting world standards through FATF requirements, among other initiatives aimed at getting off high-risk AML watchlists. AML compliance for business owners serves to protect their business’s good name, finances, and license.
An AML examination will determine whether your business structure complies with UAE AML regulations regarding monitoring activities, in-house controls, and filing requirements.
Affected entities include:
Banks, insurers, and financial services firms;
Designated Non-Financial Businesses and Professions (DNFBPs), e.g., real estate agents, precious metals dealers, accountants;
Virtual Asset Service Providers (VASPs) and related fintech entities.
Regulators now have more power to inspect, and fines or corrective actions are becoming more common.
An AML audit in the UAE usually includes:
A review of compliance policies and procedures;
Testing AML systems and controls;
Sample checks on file quality and completeness;
Validation with regulatory standards and best practices.
A successful audit shows that your documents are organized and your AML procedures work in practice, not just on paper.
The new law requires businesses to set up strong systems that:
Detect, prevent, and report suspicious activities;
Maintain customer due diligence (CDD) and Know-Your-Customer (KYC) records;
Comply with targeted financial sanctions;
Monitor transactions and file Suspicious Transaction Reports (STRs).
The new law also includes virtual assets and proliferation financing, making digital transactions and technology companies a key focus for regulators.
Investigators from the federal authorities, for instance, the Ministry of Economy, or free-zone authorities, will examine the following:
Governance Documentation: Minutes of the board of directors’ meetings, anti-money laundering policies, and information about the compliance officer.
AML Procedures: CDD/KYC procedures, risk assessment systems, STR/STR filing mechanisms.
Monitoring Records: Transaction reports, sanctions screening logbooks, high-risk indicators.
Training Evidence: Staff AML training records and communication logs.
Audit Trails: Internal or external AML audit reports and corrective plans.
Regulators must find evidence of the activity of your processes, records, and actions, not just the paperwork you keep for Anti-Money Laundering compliance in the UAE.
Here is a compliant AML checklist for UAE you can start using now:
1. Core AML Preparation
Board-approved AML policy
Appointment of AML compliance officer
CDD/KYC documentation procedures
Enhanced due diligence for high-risk clients
STR reporting and record retention system
2. Operational Readiness
Transaction monitoring tools
Sanctions screening against the UAE/UN lists
Risk assessment reports are updated annually.
Employee AML training logs
3. Documentation and Audit
Trackable audit trails
Corrective action records
Evidence of internal testing
External review reports
This AML checklist covers the main areas regulators look at during inspections, but it is not a complete list.
AML Penalties in the UAE under the Cabinet Resolution No. (134) of 2025 Concerning the Executive Regulations of Federal Decree-Law No. (10) of 2025 are much tougher than before:
Fines can match or exceed the value of criminal property involved.
Corporate fines can reach up to AED 100 million.
Managers may face personal liability.
Regulatory sanctions can include suspension or license revocation.
Recent enforcement actions, such as large fines for insurers, exchange houses, and brokers, show that regulators take non-compliance very seriously.
Consider the questions every business in the UAE should ask itself:
Does our AML framework meet the expectations of the new 2025 AML law?
Is our virtual asset and sanctions compliance up to date?
Do our internal controls pass third-party scrutiny?
Will we be able to generate on-demand documentation during reviews?
If you are unsure about any of these points, it is best to act quickly to fix any compliance gaps.
The AML regulations in the UAE keep changing, and the expectations from the regulators are very clear now. This helps in reducing the risk of penalties and enhances the position of your business in the international markets because a good compliance system helps improve the business's reputation in the global markets.
Preparation for an AML inspection in the UAE requires having systems in place to ensure compliance with the law and to safeguard the company's reputation.
It is important to assess your compliance early. AMCA’s experts help UAE businesses with these services:
Conduct AML readiness assessments;
Build robust compliance frameworks.
Provide mock audits & training;
Ensure peace of mind before regulators arrive.
FAQs
Q: What leads to an AML compliance inspection in the UAE?
The inspections are conducted by regulators on the basis of risk, as well as on reports, enforcement, and risk sector signals.
Q: How long do I have to maintain AML records?
Normally, you are required to maintain these records for 5 to 10 years. Additional scrutiny may be needed if the customers are high-risk.
Q: Does the AML compliance rule affect small businesses?
Yes, any business in the regulated industry or the DNFBP sectors must comply.
Q: Are virtual assets covered under the UAE AML law?
Yes, the 2025 AML statute clearly applies AML requirements to virtual assets and VASPs.
16 Jan 2026
