GULF CONSULT Compliance Team on
UAE AML After FATF: What the Grey List Exit Means for UAE Business Compliance
The UAE left the FATF grey list in February 2024, and a new AML law followed in 2025. What DNFBPs must have in place now.
The Financial Action Task Force removed the UAE from its list of jurisdictions under increased monitoring, the "grey list", in February 2024, after the UAE completed its action plan. That was not the end of AML enforcement. It was the start of a stricter phase.
In 2025 the UAE replaced its 2018 AML law with Federal Decree-Law No. 10 of 2025, with Cabinet Resolution No. 134 of 2025 as its executive regulations.
Are You a DNFBP?
Designated Non-Financial Businesses and Professions carry the same core AML duties as banks. They include:
- Real estate brokers and agents
- Dealers in precious metals and stones
- Auditors and accountants
- Lawyers and notaries, for certain transactions
- Corporate service providers, including company formation agents
What the Law Requires
A DNFBP must have, and be able to show an inspector:
- A documented business-wide risk assessment
- Customer due diligence, with enhanced checks for higher-risk customers
- Ongoing monitoring of customers and transactions
- Registration on the FIU's goAML platform
- Suspicious transaction reports filed without delay, whatever the amount
- A compliance officer, staff training and record keeping
Cash Transaction Reports
Dealers in precious metals and stones must report cash transactions of AED 55,000 or more through goAML. Real estate agents have their own reporting duties on cash and virtual asset purchases.
Enforcement Has Increased
Since the grey list exit, supervisors have kept up inspections and published fines. The 2025 law raises the maximum administrative fines and sets criminal penalties for running unlicensed regulated activities, so a programme that exists only on paper is now a real risk.
Frequently Asked Questions
When was the UAE removed from the FATF grey list?
In February 2024, after the FATF found that the UAE had completed its action plan.
What is the current UAE AML law?
Federal Decree-Law No. 10 of 2025, which replaced Federal Decree-Law No. 20 of 2018, with Cabinet Resolution No. 134 of 2025 as its executive regulations.
Do DNFBPs need to register on goAML?
Yes. DNFBPs must register on the Financial Intelligence Unit's goAML platform to file suspicious transaction and other reports.
What is the cash reporting threshold for gold and jewellery dealers?
AED 55,000. Dealers in precious metals and stones must report cash transactions at or above that amount.
Sources
- Lexis Middle East: FATF removed UAE from grey list
- DWF: UAE Law No. 10 of 2025 on fighting financial crimes
This article is general information, not advice for your situation. Rules change; check the current position or speak to an advisor before acting.
Need help with this? See our AML & Compliance Services.
AML & Compliance Services