Who qualifies as a DNFBP under UAE AML law?

UAE
, ,
1

Designated non-financial businesses and professions (DNFBPs) are non-financial sectors that UAE AML law brings within the regulated perimeter because of their exposure to money laundering and terrorist financing. Under the Executive Regulations they include real estate brokers and agents when concluding property purchases or sales for customers; dealers in precious metals and stones on cash or linked dealings of AED 55,000 or more; lawyers, notaries, other independent legal professionals and independent accountants when carrying out specified financial activities for clients; and company and trust service providers.

Commercial gaming operators are also designated, with their own transaction trigger. The common feature is that these businesses can be used to move, layer or disguise illicit funds, so each must register with its supervisor, apply customer due diligence, screen against sanctions lists, keep records and report to the goAML platform. Whether a firm is a DNFBP depends on the activity it performs, not merely on its trade licence category.

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

3

Five categories of DNFBP are listed. Commercial gaming operators, including gaming on vessels, at or above AED 11,000 for a single transaction or several apparently linked ones, excluding transactions solely in gaming chips or instruments. Real estate brokers and agents when concluding transactions or settlements on behalf of customers relating to the purchase or sale of real estate. Dealers in valuable metals and precious stones, for cash transactions of AED 55,000 or more, single or apparently linked.

The remaining two are professional. Lawyers, notaries, other independent legal professionals and independent accountants, whether practising alone, in partnership or within a firm, when they prepare, conduct or execute financial transactions for clients relating to buying and selling real estate, managing client funds, managing bank, savings or securities accounts, organising contributions for company formation or management, or establishing, operating, managing, buying or selling legal persons, legal arrangements or commercial entities. And company and trust service providers, for the five activities listed in the Regulations. Further businesses may be added by supervisory authority resolution.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 3: the five DNFBP categories, their activity triggers and monetary thresholds, and the power to designate further businesses.

· Federal Decree-Law No. 10 of 2025, Article 1: DNFBPs defined by reference to the activities specified in the Executive Regulations.

For your own circumstances, check your internal AML policy or speak to your compliance officer.

AML compliance self-assessment tool for DNFBPs