Are trust and company service providers subject to AML in the UAE?
Yes. Trust and company service providers (TCSPs) are DNFBPs under UAE AML law and carry the full set of preventive obligations. Because they help form companies, supply directors or nominees and provide registered addresses, they are seen as gatekeepers to corporate structures and therefore a money laundering risk if unmanaged.
A TCSP within scope must run an enterprise-wide risk assessment, apply customer due diligence and identify beneficial owners, screen clients and connected parties against sanctions and PEP lists, register on goAML and file suspicious transaction reports, appoint a compliance officer, keep records for at least five years, train staff and arrange an independent audit of its controls. The Ministry of Economy supervises the sector and inspects for compliance, with its expectations set out in Circular 4 of 2021 and the supplemental TCSP guidance.
Legal Reference (UAE):
· Cabinet Resolution 134/2025, Article 3(5) — brings company and trust service providers into the DNFBP definition.
· Federal Decree-Law 10/2025, Article 19 — sets out the preventive obligations that apply.
For more details, consult the full text of Federal Decree-Law 10/2025 or seek guidance from your AML compliance officer.