The UAE continues to enhance its AML/CFT framework to meet global standards and strengthen financial integrity. The Ministry of Economy and Tourism’s Revised Guidelines for DNFBPs (2025) set out clearer compliance expectations and a stronger focus on risk-based implementation across all sectors. This is also a major update strengthening the national AML/CFT/CPF framework and aligning with the 2024–2027 National Strategy.
Core Focus Areas
1. Risk-Based Compliance: DNFBPs must base all AML/CFT/CPF programs on business-wide risk assessments that align with the National and Sectoral Risk Assessments (NRA & SRA).
2. Governance & Accountability: Mandatory appointment of qualified Compliance Officers, board-level oversight, independent audits, and structured staff training programs.
3. Focus more on Enhanced Customer Due Diligence (CDD):
- Identify and verify customers and beneficial owners using reliable independent sources.
- Apply Enhanced Due Diligence (EDD) for PEPs, high-risk jurisdictions, Money or Value Transfer Services (MVTS) relationships, and Non-Profit Organizations (NPOs).
- Periodic and event-driven CDD reviews are now explicitly required.
4. Requirements of Policy Enhancements
- Internal AML/CFT frameworks must be:
- Documented, approved by senior management, and regularly tested.
- Integrated across all subsidiaries and affiliates, including those abroad.
5. Requirements of System Enhancement and Automation
- The DNFBPs are required to support their AML-CFT framework by adequate IT infrastructure, data analytics, and Automated systems for functions such as transaction monitoring.
Specific New Requirements
- NPOs: DNFBPs must apply tailored due diligence and sanctions screening for charities operating in or linked to high-risk jurisdictions. (section 9.3.6.5)
- MVTS Relationships: Must verify licensing, evaluate AML controls, and terminate relationships if risk cannot be mitigated. (Section 9.3.6.4)
- Recordkeeping: Retention of CDD and transaction data as per statutory timeframes. (section 11)
- STR Reporting: Immediate reporting to the FIU for any suspicion, with strict confidentiality and no “tipping off.” (Part V)
These revisions reinforce the UAE’s commitment to FATF standards and the National AML/CFT/CPF Strategy 2024–2027, ensuring DNFBPs act as key gatekeepers against financial crime. Further, These updates mark another step in reinforcing the UAE’s leadership in AML/CFT compliance and transparency. DNFBPs are encouraged to review their frameworks to ensure full alignment with the revised regulatory standards.