At what transaction amount must UAE businesses apply customer due diligence?
Under the Executive Regulations of the 2025 AML Law, customer due diligence must be applied to occasional transactions that amount to or exceed fifty-five thousand dirhams, whether carried out as a single transaction or as several transactions that appear to be linked. For occasional transactions in the form of wire transfers, the threshold is lower, at three thousand five hundred dirhams.
These thresholds apply to one off dealings with customers who are not in an ongoing business relationship. Where a business relationship exists, due diligence is required at onboarding and on an ongoing basis irrespective of any single transaction value. Due diligence is also required whenever there is a suspicion of money laundering or terrorist financing, or doubt about the accuracy of previously obtained customer information, regardless of amount.
Businesses should not treat the thresholds as a green light to ignore smaller transactions. Deliberate structuring of payments to stay below fifty-five thousand dirhams is itself a recognised red flag and may warrant enhanced scrutiny and a suspicious transaction report.
Legal Reference (UAE):
ยท Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 7 sets the AED 55,000 threshold for CDD on occasional transactions and AED 3,500 for occasional wire transfers
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 (Executive Regulations) or seek guidance from your AML compliance officer.