What risk factors must UAE firms consider when assessing money laundering risk?
The Executive Regulations set out the core risk factors a UAE firm must weigh when assessing its money laundering exposure. These are customer risk, country and geographic risk, and product, service, transaction and delivery-channel risk. A firm must consider all of these before deciding its overall level of risk and the appropriate mitigation measures.
In practice, customer risk looks at who the client is and their ownership and control; country risk looks at the jurisdictions involved; product and channel risk looks at how services are delivered, for example whether relationships are non-face-to-face. Combining these factors gives a rounded view of risk rather than relying on any single indicator, and the reasoning must be documented and kept up to date.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 5(1)(a): lists customer, country and geographic, product, service, transaction and delivery-channel risk factors.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(a): risks must be assessed across the firm’s business scope using the risk-based approach.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.
A comprehensive guide to AML customer risk assessment for DNFBPs