What ongoing transaction monitoring must DNFBPs carry out in the UAE?

UAE
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Ongoing monitoring means that a DNFBP does not treat due diligence as a one-off task at onboarding but keeps the business relationship under continuous review. The entity must scrutinise transactions carried out during the relationship to ensure they are consistent with what it knows about the customer, the customer’s business and risk profile, and, where relevant, the source of funds.

DNFBPs must also keep customer due diligence information current, reviewing and updating records rather than relying on data gathered years earlier, with particular emphasis on higher-risk customers. Monitoring should detect unusual patterns such as sudden changes in transaction size or frequency, dealings that do not fit the customer’s stated activity, or repeated transactions just below reporting thresholds. Where monitoring surfaces genuine suspicion, the DNFBP must file a suspicious transaction report on goAML. Effective monitoring is what turns a static file into a living control and is a core expectation in supervisory inspections.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution 134 of 2025 or seek guidance from your AML compliance officer.

AML Regulations for DNFBPs in UAE

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Ongoing monitoring has two limbs. You must scrutinise transactions carried out throughout the business relationship to ensure they are consistent with the information you hold about the customer, the nature of their activities and the risks they present, including, where necessary, the source of funds.

The second limb is file currency: ensuring that documents, data and information obtained during customer due diligence remain up to date and relevant, by reviewing records, with particular emphasis on records relating to categories of high-risk customers. Monitoring is therefore not only transactional. A file that has not been refreshed for a high-risk customer is a monitoring failure even if no unusual transaction has occurred.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 8(1) and (2): scrutiny of transactions for consistency, including source of funds where necessary, and keeping CDD documents up to date with emphasis on high-risk customers.

· Federal Decree-Law No. 10 of 2025, Article 19(1)(b): customer due diligence and continuous monitoring procedures scoped by risk.

For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.

Ongoing monitoring software