Who should register for goAML?
The reporting duty falls on financial institutions, designated non-financial businesses and professions, and virtual asset service providers, and it is those entities that need access to the Unit’s electronic system. On the DNFBP side that means real estate brokers and agents, dealers in precious metals and stones, lawyers, notaries and other independent legal professionals and independent accountants when carrying out the listed transactional activities, company and trust service providers, and commercial gaming operators.
Two points are often missed. The duty attaches to the activity, so a firm that carries on a listed activity is in scope even if it has never had a reportable matter, and it applies whether the business is licensed on the mainland or in a free zone. Any other business or profession can also be brought into the DNFBP definition by resolution of the supervisory authority in coordination with the National Committee, so the perimeter is not fixed. If you are unsure whether your licensed activity falls inside it, ask your supervisory authority before assuming it does not.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18(1), which places the reporting obligation on financial institutions, DNFBPs and virtual asset service providers.
· Cabinet Resolution No. 134 of 2025, Article 3, which lists the categories of designated non-financial businesses and professions.
· Cabinet Resolution No. 134 of 2025, Article 3(6), which allows further businesses or professions to be designated by resolution.
Where the position is finely balanced, document your reasoning and raise it with your compliance officer.