Anti-money laundering rules for DNFBPs: what it means for UAE businesses.

What anti-money laundering rules for dnfbps means

Also called: DNFBP, Designated Non-Financial Businesses and Professions, AML compliance.

Designated Non-Financial Businesses and Professions (DNFBPs) are the non-bank businesses that UAE anti-money laundering law treats as gatekeepers. Federal Decree-Law No. 10 of 2025, in force from 14 October 2025, replaced the 2018 law, and its Executive Regulations, Cabinet Resolution No. 134 of 2025, list the categories: real estate brokers and agents on property deals, dealers in precious metals and stones on cash transactions of AED 55,000 or more, lawyers, notaries and independent accountants when they handle client money, accounts or company matters, company and trust service providers, and commercial gaming operators.

A DNFBP must assess its money laundering risks, carry out customer due diligence, identify beneficial owners, apply sanctions instructions, appoint a compliance officer, keep records for at least five years and report suspicious transactions to the Financial Intelligence Unit. The Ministry of Economy and Tourism supervises real estate firms, precious metals dealers, accounting and audit firms and corporate service providers, and requires them to register on goAML.

For an SME in these sectors, AML is a licensing issue as much as a compliance one. Administrative fines run from AED 10,000 to AED 5,000,000 per violation, and the supervisor can suspend the activity or revoke the licence.

How it works

• Customer due diligence applies at the start of every business relationship, whenever a crime is suspected, and when earlier identification data is in doubt (Cabinet Resolution No. 134 of 2025, Article 7).
• For a corporate client, the beneficial owner is identified at 25% ownership or control, then by other control, then by senior management (Article 10).
• Suspicious transactions are reported to the Financial Intelligence Unit without delay and whatever their value, and the customer must not be told (Articles 18 and 19).
• A compliance officer at management level reviews transactions, decides on reports and runs staff training (Article 22).
• Transaction and due diligence records are kept for at least five years (Article 25).
• Supervised businesses must register on the goAML portal; the Ministry of Economy and Tourism warns that failure to register can lead to severe penalties.

Worked example

A gold jewellery shop in Dubai sells to a walk in customer who pays in cash in two visits on the same day.

First cash purchase	AED 30,000
Second cash purchase, linked to the first	AED 28,000
Total of the linked cash transactions	AED 58,000
Threshold for dealers in precious metals and stones	AED 55,000

Linked cash sales of AED 58,000 cross the AED 55,000 threshold, so the shop must apply its AML measures, starting with customer due diligence.

Common mistakes

• Thinking AML rules only apply to banks. An accounting practice, property broker or gold trader is a DNFBP in its own right.
• Splitting cash sales to stay under AED 55,000. Transactions that appear to be linked are added together.
• Registering on goAML and then never updating the risk assessment, the sanctions screening or staff training.

The law

• Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, Articles 1, 17, 18, 19, 20 and 41
• Cabinet Resolution No. 134 of 2025 on the Executive Regulations of Federal Decree-Law No. 10 of 2025, Articles 3, 7, 10, 18, 19, 22 and 25

Frequently asked questions

Why does my accountant ask for passport copies and ownership details?

Accounting and audit firms are supervised as DNFBPs. The Executive Regulations require customer due diligence at the start of a business relationship, including identifying the beneficial owners of a corporate client, and prohibit continuing where it cannot be done.

Is a general trading company a DNFBP?

Only if it carries out a listed activity, for example dealing in precious metals or stones through cash transactions of AED 55,000 or more, single or linked.

Related terms

Ultimate beneficial owner · Record retention · Audit trail · Trade licence. See every term in the UAE tax glossary.

For the full picture, read our guide: The Ultimate Beneficial Owner Register in the UAE: What Your Company Must Keep.

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