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UAE AML Supervision in 2026: DNFBP Inspections, goAML Reporting and What the New Law Changes
What Federal Decree-Law No. 10 of 2025 changes for DNFBPs, what inspectors check, and the goAML reports businesses must file.
A year after Federal Decree-Law No. 10 of 2025 replaced the UAE's 2018 AML law, DNFBPs are being inspected against the new framework and its executive regulations, Cabinet Resolution No. 134 of 2025.
What the New Law Changed
For DNFBPs, the main points are:
- Suspicious transactions must be reported to the FIU without delay and regardless of value
- Risk assessment, due diligence, monitoring and internal controls are set out as explicit duties
- Regulated activity needs a licence, registration or authorisation first
- Higher maximum administrative fines, and criminal penalties for unlicensed activity
What Inspectors Check
An inspection typically tests whether the programme works in practice, not just on paper:
- A current, documented business-wide risk assessment
- Customer files with identification, beneficial ownership and screening evidence
- Sanctions screening against the UAE local terrorist list and UN lists
- goAML registration and a record of reports filed
- Training records and an appointed compliance officer
goAML Reports
Reports are filed on the FIU's goAML platform. Besides suspicious transaction reports, dealers in precious metals and stones file reports on cash transactions of AED 55,000 or more, and real estate agents report specified cash and virtual asset purchases.
Frequently Asked Questions
What changed in UAE AML law in 2025?
Federal Decree-Law No. 10 of 2025 replaced the 2018 law, set out DNFBP duties more explicitly and raised penalties.
What do AML inspectors look for at a DNFBP?
A documented risk assessment, complete customer due diligence files, sanctions screening, goAML registration and reporting, training records and a compliance officer.
Sources
- DWF: UAE Law No. 10 of 2025 on fighting financial crimes
- Al Suwaidi & Co: Federal Decree-Law No. 10 of 2025, a practical guide for DNFBPs
This article is general information, not advice for your situation. Rules change; check the current position or speak to an advisor before acting.
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