What is the AED 55,000 threshold for customer due diligence in the UAE?

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The AED 55,000 figure is one of the thresholds that triggers customer due diligence on an occasional customer, meaning a customer with whom the business has no ongoing relationship. When a financial institution carries out an occasional transaction of AED 55,000 or more for such a customer, whether as a single transaction or several linked transactions, it must apply full customer due diligence before proceeding.

Under the Executive Regulations in Cabinet Resolution No. 134 of 2025, customer due diligence is also required at the start of any business relationship, where there is a suspicion of a crime regardless of amount, and where there are doubts about previously obtained identification data. A lower threshold of AED 3,500 applies to occasional transactions in the form of wire transfers, and the same AED 3,500 threshold applies to virtual asset service providers. Businesses should build these triggers into their onboarding and monitoring rules so that occasional high value transactions are not missed.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.

The significance of cash thresholds in fighting money laundering

AED 55,000 is the occasional transaction threshold for financial institutions. A financial institution must apply customer due diligence when conducting an occasional transaction for a customer amounting to or exceeding AED 55,000, whether as a single transaction or several that appear to be linked.

Two other thresholds sit alongside it and are often confused with it. Wire transfers carry a much lower trigger: customer due diligence applies to occasional transactions in the form of wire transfers of AED 3,500 or more, and the same AED 3,500 figure is the occasional transaction threshold for virtual asset service providers. Separately, AED 55,000 appears in the DNFBP definition as the cash threshold that brings dealers in valuable metals and precious stones into scope. None of these thresholds affect the cases where CDD always applies: starting a business relationship, suspicion of a crime, or doubt about previously obtained identification data.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 7(2)(a) and (b): the AED 55,000 occasional transaction threshold and the AED 3,500 wire transfer threshold for financial institutions.

· Cabinet Resolution No. 134 of 2025, Article 7(1) and (3): the cases where CDD always applies, and the AED 3,500 threshold for virtual asset service providers; Article 3(3): the AED 55,000 DNFBP cash threshold for dealers in valuable metals and precious stones.

Where the position is finely balanced, document your reasoning and raise it with your compliance officer.

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