Companies in the United Arab Emirates (UAE) should know these regulations and their requirements. Let´s talk facts...


The Central Bank of the UAE (CBUAE) has recently issued a new guidance on anti-money laundering, in order to track suspicious transactions and activities that may involve money laundering, terrorism financing and other criminal activities. An electronic reporting platform called goAML, was brought to life to collect and analyze financial and non-financial data to detect and combat potential financial crimes.

What is money laundering?

go AML - Anti Money Laundering
go AML - Anti Money Laundering

Money laundering defines any financial or banking transaction that intends to cover illegally obtained funds, or disguise the source of such, to avoid detection through financial and banking systems, and re-invest them into any legitimate business.

Three phases of money laundering include:

  • Placement: Depositing criminal proceeds into financial systems
  • Layering: Concealing the criminal origin of proceeds
  • Integration: Creating an apparent legal origin for criminal proceeds.


According to the UAE Ministry of Economy (MoE), all regulated entities, such as financial institutions (FIs) and the Designated Non-Financial Businesses and Professionals (DNFBPs), must register on goAML and implement respective anti-money laundering policies and controls to monitor, detect, investigate, and report on suspicious transactions, along their proper documentation.
The official registration deadline was April 30, 2021, however enrollments are still being accepted. Those who qualify are obliged to register to avoid hefty penalties and further non-compliance consequences.

According to Article 3 Cabinet Decision No. (10) of 2019, DNFBPs include:

  • Real Estate agents involved in buying and selling of real estate for their customers
  • Dealers of precious metals and stones with single or multiple related cash transactions exceeding AED 55k
  • Corporate Service Providers executing following transactions for their customers:
  1. Agents in creation/establishment of legal persons
  2. Providing Director/Secretary/Partner in a legal person
  3. Providing registered office/address of a legal person
  4. Providing Trustee functions for a Trust or similar Legal arrangement
  5. Providing nominal shareholder setup
  • Auditors and Accountants
  • Legal Consultancy Firms (Except for Lawyers and Notary Publics) preparing, conducting, and executing financial transactions for their customers related to:
  1. Purchase and sale of Real Estate
  2. Management of customer funds
  3. Management of bank, savings, or securities accounts


  • Register on the goAML system
  • Appoint independent and qualified Compliance Officer
  • Develop internal controls, policies, and procedures
  • Report Suspicious Transactions
  • Register in the automatic system for reporting sanctions lists

Penalty for non-registration on goAML

Organizations that fail to comply with the Anti-Money Laundering (AML) and Combating Financing of Terrorism requirements may face administrative fines ranging from AED 50,000 to AED 1,000,000, according to the Ministry of Economy (MoE) (Cabinet Decision No. (16) of 2021).

Your Expert

Ralf Löbker

DELTAKAP Middle East Tax Consultants

Managing Director, Tax Consultant, LL.M. (International Tax Law), CPAA (United Arab Emirates)