What is the risk-based approach (RBA) under UAE AML law?
The risk-based approach requires firms to direct their AML resources and controls in proportion to the money laundering, terrorist financing and proliferation financing risks they actually face. Rather than treating every customer and transaction the same way, a firm identifies where risk is higher and applies stronger measures there, while applying lighter measures where risk is genuinely low.
Under UAE law the risk-based approach is a legal obligation, not a matter of choice. Firms must identify, understand, manage, assess, document and continuously update their crime risks, taking the approach defined in the Executive Regulations and the results of the National Risk Assessment into account. The approach underpins customer due diligence, ongoing monitoring and the design of internal policies.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(a): firms must identify, understand, manage, assess, document and update crime risks using the risk-based approach.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 5: sets out how the risk-based approach is applied in practice.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.