➤ Introduction

The UAE’s financial crime landscape underwent seismic change with Federal Decree Law No. 10 of 2025, which came into force on October 14, 2025. This landmark legislation repeals the 2018 regime, introducing significantly tougher anti-money laundering registration requirements, expanded penalties (up to AED 100 million for legal entities and life imprisonment for serious offences), and a broader scope covering virtual assets, proliferation financing, and dual-use goods. For enterprises and financial institutions, the window for compliance is now—regulatory inspections are intensifying, penalties are severe, and reputational damage from violations is irreversible.

This practical guide explains how UAE companies can elevate their anti-money laundering registration and compliance and anti-money laundering programs to meet 2025 standards while leveraging ready-to-use templates and expert support from ASC Global UAE.

➤ Understanding UAE AML Requirements in 2025

The 2025 law fundamentally reshapes compliance obligations across three core pillars: Money Laundering (ML), Counter-Terrorist Financing (CTF), and Proliferation Financing (PF).

Core Compliance Obligations

Anti Money Laundering Registration: All Financial Institutions (FIs), Designated Non-Financial Businesses and Professions (DNFBPs), and Virtual Asset Service Providers (VASPs) must register on the goAML portal maintained by the Financial Intelligence Unit (FIU). Registration requires appointing a qualified Compliance Officer, providing business documentation, and obtaining a unique Organization ID. Failure to register results in penalties ranging from AED 50,000 to AED 1 million.

Know Your Customer (KYC) Programs: Organizations must verify customer identity through official documents (Emirates ID, passport, trade license), understand beneficial ownership structures, and assess customer risk profiles before conducting transactions. KYC documentation must be comprehensive, contemporaneous, and readily available for regulatory review.

Customer Due Diligence (CDD): Standard CDD applies to all customers; Enhanced Due Diligence (EDD) applies to high-risk customers, Politically Exposed Persons (PEPs), and complex ownership structures. CDD must precede transaction execution—if checks aren’t completed, transactions should not proceed.

Vendor Screening and Ongoing Monitoring: Continuous screening against UAE National Sanctions Lists, global OFAC lists, and PEP databases is mandatory. Transaction monitoring must identify suspicious patterns, unusual activity, and threshold breaches with automated alerts and escalation procedures.

Governance and Escalation: Board-level oversight, documented policies, escalation procedures, and audit-ready record-keeping are non-negotiable. Organizations must maintain evidence of compliance for regulatory inspections.

Key Regulatory Shifts Under the 2025 Law

The new regime lowers evidentiary thresholds for ML offences—knowledge is no longer required; liability can arise where a person "knew, or had sufficient evidence or circumstantial evidence to support his knowledge" that the funds were illicit. Individual penalties for money laundering range from AED 100,000 to AED 5 million (up to AED 10 million for aggravated cases or for Terrorist Financing). Legal entity fines for ML can reach up to AED 100 million. The law’s scope expands to virtual assets, proliferation financing, arms-related dual-use goods, and now explicitly includes direct and indirect Tax Evasion as a Predicate Crime.

➤Practical Steps to Elevate AML Compliance: Actionable Checklist

Step 1: Confirm AML Registration Requirements

Determine if your organization falls under mandatory registration categories: FIs (banks, insurance, investment firms), DNFBPs (lawyers, accountants, real estate agents, dealers in precious metals/stones), or VASPs (cryptocurrency exchanges, wallet providers).

Action: Consult compliance advisors if classification is unclear. Registration delay triggers penalties and regulatory scrutiny.

Step 2: Register on goAML Portal

Complete anti money laundering registration through the following process:

• Appoint a qualified Compliance Officer with Emirates ID, passport, valid visa, and authorization letter
• Gather business documentation (trade license, ownership structure, business activities list)
• Register on SACM (Service Access Control Manager) portal for goAML access credentials
• Log into goAML, complete the company profile with business details and Compliance Officer credentials
• Submit application for FIU review and approval
• Receive a unique Organization ID upon approval

Timeline: Registration typically completes within 2-4 weeks with complete documentation.

Step 3: Implement KYC and CDD Protocols

Develop comprehensive KYC procedures covering:

• Customer identification and verification through official documents
• Beneficial ownership discovery for corporate entities (trusts, nominee structures)
• Source of wealth and source of funds investigation
• Risk classification (low, medium, high) based on customer profile, jurisdiction, and business nature
• EDD procedures for high-risk customers, PEPs, and complex structures

Best Practice: Document all KYC steps contemporaneously—regulatory inspections typically review customer files for evidence of proper CDD completion.

Step 4: Screen Vendors and Conduct Ongoing Monitoring

Establish automated screening protocols:

• Screen all customers and vendors against the UAE National Sanctions List, OFAC lists, and PEP databases at onboarding
• Conduct continuous screening at defined intervals (monthly minimum recommended)
• Set automated alerts for threshold breaches, unusual transaction patterns, and geographic anomalies
• Configure transaction monitoring by customer risk tier
• Escalate suspicious transactions to the Compliance Officer for investigation and potential Suspicious Transaction Report (STR) filing

Critical: STR submissions to goAML within timelines prevent fines and demonstrate regulatory good faith.

Step 5: Establish Governance and Record-Keeping

Board-level governance requires:

• Board-approved AML policies aligned with 2025 law requirements
• Documented escalation procedures and decision-making authority
• Regular Compliance Officer reporting to senior management and board audit committees
• Audit trails and contemporaneous documentation of compliance decisions
• Annual compliance certifications and internal audit reviews
• Staff training programs covering AML obligations, sanctions screening, and reporting procedures

➤Ready-to-Use Templates and Checklists

KYC Procedure Template

➤Vendor Onboarding Checklist

• ☐ Obtain vendor corporate registration and trade license
• ☐ Conduct beneficial ownership verification
• ☐ Verify vendor’s regulatory status and compliance certifications
• ☐ Screen against sanctions lists and PEP databases
• ☐ Assess vendor’s own AML compliance program
• ☐ Document due diligence in vendor file
• ☐ Establish ongoing monitoring schedule
• ☐ Escalate any red flags to Compliance Officer

➤Transaction Monitoring Threshold Examples

➤How ASC Global UAE Helps Elevate Compliance

ASC Global UAE provides specialized financial services, risk advisory and implementation support:

• Anti Money Laundering Registration Support: We guide clients through goAML registration, documentation preparation, SACM portal navigation, and FIU approval processes—typically completing registration within 2-3 weeks.
• Customized AML Policy Development: We design policies aligned with 2025 law requirements, your specific sector, and organizational risk profile. Policies integrate KYC procedures, CDD protocols, transaction monitoring thresholds, and governance frameworks.
• Practical Template and Toolkit Provision: We provide ready-to-use KYC forms, vendor screening checklists, monitoring templates, and escalation procedures adaptable to your operations—reducing implementation time from months to weeks.
• Compliance Monitoring and Advisory: We conduct quarterly compliance health checks, transaction monitoring quality reviews, and governance assessments, ensuring sustained compliance as regulations evolve.
• Training and Awareness Programs: We deliver staff training on AML obligations, sanctions screening, reporting procedures, and compliance and anti-money laundering best practices, ensuring organizational readiness for regulatory inspections.

➤ FAQs

Q1: How does anti money laundering registration work in UAE?

A1: Organizations falling under FI, DNFBP, or VASP categories must register through the goAML portal via SACM access, appoint a Compliance Officer, provide business documentation, receive FIU approval, and obtain a unique Organization ID for reporting and portal access.

Q2: What are penalties for AML non-compliance in UAE?

A2: Penalties for registration and compliance violations typically range from AED 50,000 to AED 1 million (with serious non-compliance fines reaching up to AED 100 million for legal entities). Money laundering offences carry AED 100,000 to AED 10 million fines for individuals. Terrorist financing carries up to life imprisonment.

Q3: How often should KYC/customer due diligence be updated?

A3: Initial KYC is required before transaction execution. CDD updates should occur annually minimum, or immediately upon material changes in customer profile, risk classification, or regulatory designation changes.

Q4: What are best practices for vendor screening in UAE AML?

A4: Conduct comprehensive beneficial ownership verification, screen against sanctions and PEP databases at onboarding and continuously, assess vendor’s own AML compliance program, document findings, establish monitoring schedules, and escalate red flags immediately.

➤ Conclusion

Federal Decree Law No. 10 of 2025 marks a turning point for UAE enterprises and financial institutions. Compliance is no longer optional—it's a strategic imperative protecting your operations, reputation, and competitive standing. Organizations embracing robust anti-money laundering registration and governance frameworks position themselves as trusted market leaders, while those delaying face severe penalties, license revocation, and irreversible reputational damage.

The practical steps, templates, and checklists in this guide provide a clear implementation roadmap. However, the 2025 law's complexity and real consequences make expert guidance invaluable. Early adopters who act now will navigate the regulatory landscape with confidence while attracting institutional partnerships and reducing operational risk.

The window for compliance is now. Don't navigate this transformation alone.

Ready to secure your organization's AML compliance?

ASC Global UAE delivers:
✓ AML registration within 2-3 weeks
✓ Ready-to-use templates & governance frameworks
✓ Sector-specific expertise
✓ Ongoing compliance monitoring

Contact ASC Global UAE Today:
📞 Call: +971503287722
💬 WhatsApp:  https://wa.me/971503287722
🌐 Visit: www.ascglobal.ae
📩 Email: info@ascglobal.ae

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