Anti money laundering & Countering Terrorist Financing organisations (AML & CFT) law aims to combat money-laundering practices, terrorist training and establishes a legal framework that supports the concerned authorities with anti-money laundering and crimes related to money-laundering, counter the financing of terrorist operations and suspicious organisations.


Designated Non-Financial Businesses and Professions (DNFBPs) are sectors that are vulnerable to money laundering and terrorism financing risks, such as real estate agents, dealers in precious metals and stones, lawyers, accountants, corporate service provider etc.

DNFBPs are required to register with their respective authorities and appoint one person as a Money Laundering Reporting Officer (MLRO). This firm should report any Suspicious transactions (STRs) to Financial Intelligence Unit (FIU).

As a firm who is a DNFBPs need to do a risk-based assessment on all the clients onboard & evaluate periodically their credentials. Maintain a detailed register for the company and their clients. Subscribe for the risk assessment companies like LexisNexis, World check, Thomas Reuters which allows screening of the firm / individual status. Every firm need to register with Executive Office for control and non-proliferation (ECON) to get the emails on the latest list of sanction countries and sanctioned person’s name.

In case of any negative report do further investigation and once confirmed report STR with FIU.

In a risk bound approach the client can be evaluated as follows:

1.       Activity:  like trading in bullions, precious metal hazardous chemicals

2.       Type of licence:  General trading, Management consultancy

3.       Complicated Structure of the organisation

4.       Are they under any sanctioned list of countries or person.

5.       Have internal money laundering policies.

Risk based approach requires a Risk based assessment of a relevant person’s business and its customers. A Risk based assessment is a dynamic process involving regular review, and the use of these reviews to establish the appropriate process to match the level of risk. Company has relied upon the tools provided by world check compliance for screening and sanction monitoring of its customers. These tools include FATF recommendations and UNSC renewed data. Such system is reasonable and appropriate in light of the AML risk it covers. Following areas are covered with respect to assessment of risk of customers:

1. No of customers

2. Type of customers

3. The countries in which the customers do their business

4. The geographic area in which customers do their business

5. Customer’s products, services, and activity profiles

6. Its distribution channels and business partners

7. The complexity and volume of its transactions

8. Including new delivery mechanisms, channels, and partners; and

9. Any new customers during the year

10. Any changes in the business profile

M&M Al Menhali Auditing provides Audit and Assurance Services in Dubai, UAE and has developed expertise to comply with AML / CFT regulations in Dubai, UAE. Clients looking for Compliance services in Dubai, UAE can get in touch with M&M Al Menhali Auditing.


Our Compliance services cover:

1.       AML / CFT regulations in Dubai, UAE

  • Economic substance regulations in UAE
  • UBO declaration in Dubai, UAE
  • ICV certification in Dubai, UAE

Some important acts and circulars of federal legislation governing Anti-Money Laundering (AML) in UAE are:

Laws / Cabinet decision / CircularsDescription
Federal Law No. 4 of 2002Concerning Combating Money Laundering and Terrorism Financing Crimes  
Federal Law No. 1 of 2004Decree on Combating Terrorism Offences
Federal Decree by Law No. (20) of 2018On Anti Money Laundering and Combating the Financing of Terrorism
Cabinet Decision 10 of 2019regarding the executive regulations for crimes of money laundering and terrorist financing 
Cabinet Decision No. (74) of 2020regarding the terrorist list system and the implementation of Security Council resolutions related to preventing and suppressing terrorism and its financing
Cabinet Resolution No. (16) of 2021regarding the consolidated list of violations and administrative fines inflicted on violators of anti-money laundering measures.
Cabinet Decision No. (24) of 2022 amending Cabinet Decision No. (10) of 2019Executive Regulations of Decree-Law No. (20) of 2018 Confronting and Combating Money Laundering Offenses.  
Ministerial Decision No. (532) of 2019regarding the establishment of the Anti-Money Laundering Department 2019
Decision of the Minister of Justice No. 533 of 2019regarding the procedures for combating money laundering and financing of terrorism for lawyers, notaries and professionals
Circular No. 36 of 2020Regarding International and local sanction list
Circular No. (18)regarding lawyers’ implementation of their obligations to report clients on international or local sanctions lists
Circular No. 9 of 2022 ADregarding the implementation by lawyers of the targeted financial penalties prescribed by Security Council resolutions. 
Circular No. 14 of 2022regarding the REAR Real Estate Activities Report 
Circular No. (1) of 2023regarding the commitment of law firms to the controls of institutional assessment processes, the risks of financing proliferation
Circular No. 2 of 2023regarding the obligations of lawyers regarding the updated list of high-risk countries and countries subject to strict control and countermeasures to be applied.