At what transaction amount is customer due diligence required in the UAE?
There is no single figure, because the trigger depends on who you are. For every financial institution, DNFBP and virtual asset service provider, customer due diligence is required on commencing a business relationship, wherever there is suspicion of a crime, and wherever there are doubts about the accuracy or adequacy of identification data previously obtained. None of those three triggers has a monetary threshold at all.
Value thresholds apply only to occasional transactions and only to certain sectors. Financial institutions must apply customer due diligence on occasional transactions of AED 55,000 or more, whether as a single transaction or several that appear to be linked, and on occasional wire transfers of AED 3,500 or more. Virtual asset service providers apply it at AED 3,500 for occasional transactions. Dealers in precious metals and stones are DNFBPs on cash transactions of AED 55,000 or more, and commercial gaming operators at AED 11,000. Real estate brokers and agents have no monetary threshold: the obligation attaches to the activity of concluding a purchase or sale for a customer.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 7(1), which requires customer due diligence on commencing a business relationship, on suspicion of a crime, and where there are doubts about previously obtained identification data.
· Cabinet Resolution No. 134 of 2025, Article 7(2) and (3), which set the AED 55,000 and AED 3,500 occasional-transaction thresholds for financial institutions and the AED 3,500 threshold for virtual asset service providers.
· Cabinet Resolution No. 134 of 2025, Article 3, which sets the AED 55,000 cash threshold for dealers in precious metals and stones and the AED 11,000 threshold for commercial gaming operators, with no monetary threshold for real estate brokers and agents.
For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.