
The UAE has significantly strengthened its framework for combating financial crime with the introduction of **Federal Decree-Law No. 10 of 2025**, which updates the country‚ As Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) laws. This new legislation underscores the UAE‚As commitment to upholding the highest standards of financial integrity and aligning with the recommendations of the Financial Action Task Force (FATF). [1]
For businesses in the UAE, particularly those designated as **Designated Non-Financial Businesses and Professions (DNFBPs)**, understanding and complying with this new law is not just a legal requirement‚ it is a critical component of corporate governance and risk management. The authorities are intensifying scrutiny, and the penalties for non-compliance are severe.
This guide provides a clear explanation of the key aspects of the new AML/CFT law and what they mean for your business. We cover the scope of the law, the key obligations for DNFBPs, and the steps you need to take to ensure you are fully compliant. And when you need expert assistance, T4me‚As legal and compliance specialists are here to help you navigate the complexities of AML/CFT regulations.
What are DNFBPs?
DNFBPs are businesses and professions that are considered to be at a higher risk of being used for money laundering or terrorist financing. In the UAE, this category includes:
- Real estate agents and brokers
- Dealers in precious metals and precious stones
- Lawyers, notaries, and other independent legal professionals
- Accountants and auditors
- Trust and company service providers
If your business falls into one of these categories, you have specific legal obligations under the AML/CFT law.
Key Obligations for DNFBPs under the New Law
The new law reinforces and expands the obligations for DNFBPs to prevent financial crime.
- Conduct a Risk Assessment: You must assess the risks your business faces from money laundering and terrorist financing. This involves identifying your high-risk clients, services, and geographical areas of operation.
- Implement a Compliance Program: You must develop and implement an internal AML/CFT compliance program. This includes appointing a compliance officer, providing staff training, and establishing written policies and procedures.
- Customer Due Diligence (CDD): You must conduct due diligence on your customers to verify their identity and understand the nature of their business. This is often referred to as ‚Know Your Customer‚(KYC).
- Report Suspicious Transactions: You have a legal obligation to report any suspicious transactions or activities to the UAE‚As Financial Intelligence Unit (FIU) through the ‚ goAML portal.
- Maintain Records: You must maintain records of all customer transactions and due diligence for a period of at least five years.
What`s New in the 2025 Law?
The new Federal Decree-Law No. 10 of 2025 introduces several enhancements to the existing framework:
- Stricter Enforcement and Penalties: The law provides for stricter penalties for non-compliance, including substantial fines and potential imprisonment.
- Enhanced Scope: The scope of the law has been clarified and potentially expanded to ensure that all relevant entities are covered.
- Greater Emphasis on Risk-Based Approach: The new law places even greater emphasis on the need for businesses to adopt a risk-based approach to AML/CFT compliance.
How T4me (t4me.com) Can Help Your Business with AML/CFT Compliance
AML/CFT compliance can be a complex and resource-intensive task. T4me (t4me.com) offers a range of services to help DNFBPs and other businesses meet their legal obligations.
Our services include:
- AML/CFT Health Check: We can conduct a review of your current policies and procedures to identify any gaps in your compliance program.
- Development of Compliance Programs: We can help you to develop a tailored AML/CFT compliance program that meets the specific needs of your business.
- Staff Training: We can provide training for your staff to ensure they are aware of their obligations and can identify suspicious activities.
- Assistance with Reporting: We can provide guidance on how to file suspicious transaction reports with the FIU.
Frequently Asked Questions (FAQ)
1. Does the AML/CFT law apply to my business if it is not a DNFBP?
While the most stringent requirements apply to financial institutions and DNFBPs, all businesses in the UAE are expected to be aware of the risks of financial crime and to report any suspicious activity they encounter.
2. What is the ‚ goAML portal?
The goAML portal is the online platform used to report suspicious transactions to the UAE‚As Financial Intelligence Unit.
3. What is the difference between a compliance officer and a money laundering reporting officer (MLRO)?
These terms are often used interchangeably. The key role is to have a designated individual who is responsible for overseeing the company‚ As AML/CFT compliance program.
4. What are the consequences of failing to report a suspicious transaction?
Failing to report a suspicious transaction is a serious offense and can result in significant fines and criminal charges.
5. How often should I review my company‚ As risk assessment?
You should review your risk assessment on a regular basis, and especially when there are changes to your business, such as the introduction of new products or services.
Conclusion: A Collective Responsibility
Combating financial crime is a collective responsibility, and the UAE government is taking a firm stance to protect the integrity of its financial system. The new AML/CFT law is a clear signal that all businesses must play their part.
By taking a proactive approach to compliance, you can not only avoid the severe penalties for non-compliance but also protect your business from the reputational and financial risks associated with financial crime.
Contact T4me (t4me.com) today for a confidential consultation on your AML/CFT compliance needs. Let our experts help you to build a robust compliance program and safeguard your business.
References
[1] ProAct. “UAE AML/CFT Law ‚ Federal Decree-Law No. 10 of 2025 – Guide.” linkedin.com, 10 Dec. 2025, https://www.linkedin.com/pulse/uae-amlcft-law-federal-decree-law-no-10-2025-guide-proactuae-s1cxcjfpcfeofxqc.