What ongoing AML training must DNFBP staff receive under UAE law?
UAE AML law requires DNFBPs to deliver ongoing, role-based AML/CFT/CPF training to all relevant staff. Training must cover the legal framework under FDL 10/2025 and Cabinet Resolution 134/2025, the entity’s internal policies, current ML and TF typologies, the National Risk Assessment outcomes, sanctions screening, beneficial ownership rules under Cabinet Resolution 109/2023, and the procedure for internal escalation of suspicions to the MLRO.
The frequency must be at least annual, with refresher sessions whenever there is a regulatory update, a change in the entity’s risk profile, the issuance of new circulars or typology reports, or onboarding of new staff. Front-office personnel need red-flag awareness tailored to the customer-facing activity they perform. Compliance officers and the MLRO need deeper technical content covering CDD, transaction monitoring, sanctions screening logic and STR drafting. Senior management and board members need governance-level briefings covering supervisory expectations, accountability, and the entity’s residual risk position.
Training records, including content, attendance, knowledge-check results and remediation for staff who fail assessments, must be retained for five years for supervisory inspection. The Compliance Officer should report training completion to senior management at least annually as part of the AML programme report. Supervisors expect tailored content for higher-risk roles and treat off-the-shelf generic training as a deficiency under the risk-based approach.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Article 21 — ongoing training requirement
- Federal Decree-Law No. 10 of 2025, Article 16 — staff training duty for DNFBPs
For more details, consult the full text of Cabinet Resolution 134/2025
Complete Guide to Employee Training Against Financial Crimes