AML & ESR Compliance Services in UAE for Regulatory Readiness

The current federal AML framework is set out in Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, which contains the applicable executive regulations.

AML duties depend on licensed and/or conducted operations, customer dealings and supervisory body. Financial institutions, Designated Non-Financial Businesses and Professions, Virtual Assets Service Providers, and other supervised enterprises would have certain needs.

The DNFBP definition encompasses certain activities that are conducted by:

The service includes AML applicability assessment, gap analysis, goAML registration assistance, risk assessment, policies, KYC/CDD processes, checks for Beneficial Owners, sanctions controls, reporting, record keeping and ESR historical records review. This will depend on the nature of business being done by the entity.

AML Applicability and Gap Analysis

The following are considered – the trade license, offered services, customer base, transaction types, ownership structure and compliance documentation available. This will be an attempt to determine applicability of the regulated sector and where the process needs to be done.

The gap analysis will reveal that there are out-of-date policies, incomplete gap analysis, unclear responsibilities and absence of KYC, screening or monitoring activities.

goAML Registration and Profile Assistance

goAML enables the reporting entity to submit the defined reports to the UAE FIU. Registration criteria needs to be verified with the relevant regulatory body.

Our goAML registration UAE support may consist of the following services – document checklist, user verification and Reporting Entity profile support.

Company-wide AML Risk Assessment

A general risk template might not represent actual risks faced by the company. Our AML risk assessment UAE takes into consideration customers, jurisdictions, products, services, transaction patterns, payment methods, and delivery channels.

This analysis looks into ownership structure, jurisdiction, payment methods, onboarding methods, and unusual transactions for development of a risk rating process.

KYC, CDD, and Enhanced Due Diligence

Customer Due Diligence is not about obtaining an Emirates ID or trading license only. The company may have to know the customer, identify and verify a beneficial owner, determine the purpose of the relationship, and compare actual and anticipated transactions.

Our KYC and CDD solutions UAE can assist in developing a proper onboarding procedure, customer risk ratings, reviews and approvals. In case of high-risk relationships, we can conduct source-of-funds/source-of-wealth review and senior management approval.

PEP, Sanctions, and Transaction Monitoring Controls

The AML Policy & Procedures UAE should include the procedures on dealing with politically exposed persons, sanctions, unusual ownership and transaction monitoring. Our company helps structure the screening documentation, escalation and decision making process according to the respective requirements and risks.

Internal Reporting and STR Workflow

Where a reporting entity suspects, or has reasonable grounds to suspect, that transactions, attempted transactions or funds are related to a Crime, it must notify the Financial Intelligence Unit immediately and without delay through the approved electronic system. This obligation applies regardless of the transaction value.

GetMyAccounting can help organise red flags, staff escalation steps, confidential case records and non-tipping-off controls. The authorised Compliance Officer and reporting entity retain responsibility for evaluation and reporting decisions. A limited exception applies to certain lawyers, notaries, independent legal professionals and independent statutory auditors where information was obtained in the specified legal or advisory circumstances under Article 18(2); this is not a broad exemption from STR obligations.

Policies, Training and Record Management

Policies should reflect the company's risks, carry senior-management approval, assign responsibilities and address training and testing where applicable. Under Cabinet Resolution No. 134 of 2025, Article 25, covered records must generally be retained for at least five years, with the starting point depending on the record type and applicable event. For certain records, the period may run from the latest relevant event, including the end of the business relationship, account closure, inspection, investigation or final judgment.

For businesses whose financial information is disconnected from their compliance files, our accounting and bookkeeping services can help organise the underlying ledgers, invoices and transaction records. The AML & ESR Compliance Services in UAE engagement can be limited to one defined requirement or expanded into a structured review, depending on the condition of the existing records and procedures.

The requirements of Economic Substance as separate requirements have been put to an end for the fiscal year starting after 31 December 2022 due to Cabinet Decision No. 98 of 2024. There could be a scenario where assistance may be required in respect of pending notifications/reports/assessments/documentation related to historical fiscal years from 1 January 2019 to 31 December 2022.

The UAE Ministry of Finance's official Economic Substance update confirms this position and notes that companies remain responsible for applicable obligations, information requests and amendments relating to earlier periods.

Our historical ESR review UAE support can examine the financial year, activity, Relevant Income, exemption basis, previous filings and authority correspondence. It is not presented as a new annual filing requirement for post-2022 periods.

Standalone ESR and UAE Corporate Tax are separate areas. A Free Zone or group company with questions about its current tax position can also review our Corporate Tax Advisors in UAE service.

A new framework for all organizations is not always required. Prior to starting our work, we clarify the problem and deliverables.

• Documents regarding trading license, incorporation, ownership and signatures
• Policy Documents, Risk Assessment and Compliance Officer Documents
• Onboarding Customer, Risk Rating and Sample KYC Documents
• PEP Screening, Sanctions Screening and Monitoring Documents
• goAML, Training and Internal Review Documents
• Previous ESR submissions where applicable

This list will vary depending upon the scope of review.

1. 1
   Step 1: Analysis of the Business

   We analyze the activity, license, client base, ownership, payment systems and supervisory role.

2. 2
   Step 2: Controls Assessment

   The policies, risks assessment, client documentation, portal analysis and history are analyzed.

3. 3
   Step 3: Gap Prioritization

   The gaps are determined, scope is confirmed and the necessary policies and registers are prepared.

4. 4
   Step 4: Implementation and Reassessment

   The responsible team is coached regarding onboarding, screening, escalation and documentation. Management evaluates the procedures and assigns responsibility.

GetMyAccounting relates compliance policies to accounting files, proof of ownership, business transaction processing, customer on-boarding and management approval.

With our services, you will benefit from:

• Scopes that are real-world and related to your regulatory position
• References from current regulations and practical checklists
• Distinct sections for AML, ESR and corporate tax historically
• Identification of record gaps early
• Deliverables and responsibility mapping defined

We do not guarantee regulatory approval, inspection results and any protection against fines. The decision lies with the relevant authorities.

The businesses in UAE should evaluate their AML policy on the basis of the present regulatory environment, operations, customer risk profile, business structure and transactions. The AML policies, due diligence documents and roles within the business should be revised each time there is a change in the business or requirement.

GetMyAccounting AML & ESR Compliance Services in UAE help the businesses evaluate existing measures, organise their compliance documentation and review past ESR issues. This will assist management to understand its compliance standing and the areas where the review may be required.