What AML obligations apply to company service providers in the UAE?
Company service providers in the UAE must operate a full AML/CFT programme. The core obligations are: register on the goAML portal, appoint an AML compliance officer, carry out an enterprise-wide money laundering, terrorist financing and proliferation financing risk assessment, and apply customer due diligence with enhanced measures for higher-risk clients. They must identify and verify the beneficial owner behind every corporate client and understand the purpose and control structure of the entity.
Providers must also screen clients and connected parties against the UN and UAE sanctions lists, subscribe to the EOCN notification system, monitor relationships on an ongoing basis, keep records for at least five years, train staff, and commission an independent audit of the programme. Any suspicion of money laundering must be reported to the FIU without delay. MoET Circular No. 4 of 2021 sets out these expectations for the sector in detail.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 - core preventive obligations for DNFBPs.
· Federal Decree-Law No. 10 of 2025, Article 20 - requires licensing or registration to carry on DNFBP activity.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.