What extra checks apply to politically exposed persons under UAE AML law?
Politically exposed persons attract enhanced due diligence under the UAE AML framework because of the higher risk of corruption and abuse of position they can represent. For foreign politically exposed persons, regulated entities must put in place risk management systems to determine whether a customer or beneficial owner is a PEP, obtain senior management approval before establishing or continuing the relationship, take reasonable measures to identify the source of funds and wealth, and conduct enhanced ongoing monitoring.
For domestic politically exposed persons and people entrusted with prominent functions in international organisations, entities must take adequate measures to determine whether the customer or beneficial owner falls within these categories, and apply the same enhanced measures where the relationship is high risk. Life insurance providers must also check whether the beneficiary or its beneficial owner is a PEP before paying out, and escalate to senior management where higher risks are identified. These measures apply in addition to standard customer due diligence.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 16 — enhanced measures for politically exposed persons.
· Federal Decree-Law No. 10 of 2025, Article 19 — customer due diligence and risk-based obligations.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.