AML compliance for DNFBPs in the UAE
Real estate brokers, gold and jewellery dealers, corporate service providers and accountants in the UAE must run a working AML programme. We set it up, keep it running and stay with you when the Ministry of Economy and Tourism comes to inspect.
Book a free AML check on WhatsApp
Does this apply to your business?
Since 14 October 2025 the UAE applies Federal Decree-Law No. 10 of 2025, and since 14 December 2025 its Executive Regulations, Cabinet Resolution No. 134 of 2025. A business becomes a designated non-financial business or profession (DNFBP) by what it does, not by the name on its licence. The main groups:
- real estate brokers and agents;
- dealers in precious metals and stones, for cash transactions of AED 55,000 or more;
- company and trust service providers: formation agents, registered office, nominee directors and shareholders;
- independent accountants and legal professionals for specific client transactions;
- commercial gaming operators, for transactions of AED 11,000 or more.
On the mainland and in commercial free zones real estate brokers, precious metals dealers, company service providers and accountants are supervised by the Ministry of Economy and Tourism (MOET). The full picture of the new rules is in our guide New UAE AML Law for DNFBPs.
What we do
AML Setup
One-off, from zero to compliant
- goAML registration and EOCN registration for sanctions list notifications
- AML/CFT/CPF policy and procedures for your sector, with KYC forms
- business risk assessment based on the National Risk Assessment, method disclosed to you
- one-hour briefing for owners and management
Ongoing Compliance
Monthly support
- control of customer due diligence and sanctions screening
- decisions on suspicious transactions and goAML reports
- annual update of the risk assessment and the policy
- staff training once a year and a quarterly report to management
- correspondence with MOET and support during inspection
Compliance Officer
Outsourced role
- an Atlant Capital specialist acts as your appointed compliance officer
- appointment after prior approval of MOET, as the Regulations require
- your internal deputy stays in the loop, records of every decision are kept
One-off services
- goAML and EOCN registration on their own;
- AML policy and KYC forms, or an update of existing documents to the new law;
- business risk assessment or its annual update;
- staff training, 2 to 3 hours in English or Russian, with a test and certificates;
- mock inspection: one day on site along MOET inspection logic, report and remediation plan;
- response to a MOET request and remediation of inspection findings.
Why Atlant Capital
Certified for DNFBPs
Our compliance lead holds the ICA and MOET Certificate in AML/CFT for DNFBPs with Distinction, issued in October 2026.
Built around your real business
Company formation, licence changes and bank accounts are our daily work, so the AML programme follows how your company actually operates, not a template.
English and Russian
Documents in English for the regulator. Explanations to owners and staff training in Russian or English.
Why it matters
In the first half of 2025 MOET recorded 1,063 AML violations among real estate brokers, precious metals dealers, corporate service providers and auditors, with fines above AED 42 million. Under the new law a fine can reach AED 5,000,000 per violation.
How we work
- Free AML check, 30 to 45 minutes: we look at your activity and tell you whether you are a DNFBP and what is missing.
- A clear offer: scope, list of documents, price.
- Setup: registrations, policy, risk assessment, briefing.
- Ongoing support, or a clean handover to your own team.
What we do not take
Virtual asset service providers licensed by VARA, and entities in DIFC or ADGM: these are separate regimes. We also do not audit the AML programme of a company where we act as compliance officer, because the independent review must stay independent.
Get a free AML check
Tell us what your company does and we will tell you which AML obligations apply and what is missing.
Or write to main@atlant-capital.ae. Starting a new company? See company setup in the UAE.
FAQ
Is my company a DNFBP?
It depends on what the company actually does, not on the name of the licence. Real estate brokers and agents, dealers in precious metals and stones, company and trust service providers, independent accountants and commercial gaming operators can fall under Cabinet Resolution No. 134 of 2025. Our free AML check gives you a clear answer for your activity.
Can an external specialist be our compliance officer?
Yes. The role can be outsourced, but every appointment needs prior approval of the supervisor (Article 49(18) of Cabinet Resolution No. 134 of 2025), and senior management of the company keeps the final responsibility for the AML programme. We prepare the documents and support the approval.
What happens if a DNFBP has no AML programme?
Under Federal Decree-Law No. 10 of 2025 administrative fines run from AED 10,000 to AED 5,000,000 per violation, alongside measures from a warning to licence revocation, and the supervisor may publish the penalties it imposes.