Vikas Dhingra
Chief Financial Officer · Tax & Structuring
UAE AML Compliance
& DNFBP Support
Risk-based AML programme design, MLRO support, goAML portal registration, STR/SAR filing and sanctions screening — for UAE DNFBPs and obliged entities.
- AML / CFT
- DNFBP Coverage
- goAML Portal
- MLRO Support
- Sanctions Screening
AML Programmes Built to the UAE Federal Framework
UAE AML compliance applies across the financial sector and to Designated Non-Financial Businesses and Professions (DNFBPs) under Federal Decree-Law No. 10 of 2025 (which replaced Decree-Law No. 20 of 2018). Obliged entities must run a risk-based AML programme, register on the Financial Intelligence Unit's goAML portal, appoint a Money Laundering Reporting Officer, screen sanctions, and file STRs and SARs. Avyanco delivers this end-to-end.
UAE AML and counter-terrorism financing obligations apply across the financial sector and across Designated Non-Financial Businesses and Professions (DNFBPs) — real estate brokers and agents, dealers in precious metals and stones, auditors, corporate service providers, lawyers and notaries. The framework is set out in Federal Decree-Law No. 10 of 2025 on AML/CFT and proliferation financing (which replaced Federal Decree-Law No. 20 of 2018 with effect from 14 October 2025) and the implementing Cabinet Decisions. Obliged entities must implement a risk-based AML programme, register on the UAE Financial Intelligence Unit's goAML portal, appoint a Money Laundering Reporting Officer (MLRO), screen against international and UAE sanctions lists, and file Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) as required.
Avyanco's AML practice covers programme design, MLRO support, goAML portal registration, sanctions screening setup, ongoing transaction monitoring, training and FIU correspondence. Engagements are scoped to the entity's actual risk profile — sector, customer base, geography and product mix — not boilerplated. Programme documentation is built to support both regulator review and UAE bank ongoing KYC.
How AML Compliance Works
Six steps from scoping through ongoing operation.
- 01
DNFBP Scoping
Confirm whether the entity falls within the DNFBP definition or other obliged-entity category, and identify the supervisory authority (Ministry of Economy, Ministry of Justice, Central Bank of the UAE, SCA, or the DIFC/ADGM regulators DFSA/FSRA).
- 02
Risk Assessment
Customer, product, geography and delivery-channel risk assessment to set the risk-based AML programme.
- 03
Policy & Procedures
AML policy, KYC procedures, enhanced due diligence triggers, sanctions screening procedures, transaction monitoring framework and STR/SAR filing procedures.
- 04
MLRO Appointment & goAML Registration
Money Laundering Reporting Officer (MLRO) appointed and goAML portal registration completed with the UAE FIU.
- 05
Sanctions Screening Setup
Customer and transaction screening against UN, OFAC, EU, UK and UAE local sanctions lists — integrated with onboarding KYC and ongoing monitoring.
- 06
Training & Ongoing Monitoring
Staff training, periodic programme review, transaction monitoring and STR/SAR filing as required.
Why Use Avyanco for AML
AML is a programme, not a checklist. The advantage is in how it's designed and run.
Risk-based programme design — scaled to the entity's actual risk profile
DNFBP supervisory authority correspondence handled end-to-end
goAML portal registration and ongoing STR/SAR filing support
Sanctions screening against UN, OFAC, EU, UK and UAE local lists
MLRO support — staffing, training, ongoing escalation framework
AML programme documentation built for regulator review and bank KYC
Periodic programme review and risk re-assessment
Integration with tax, audit and corporate-secretarial engagements
The Avyanco Advantage
Six things that distinguish Avyanco's AML practice.
Risk-Based Design
Programme scaled to the entity's actual customer, product, geography and delivery-channel risk — not boilerplated.
Documentation Built Right
Policies, procedures and operating documents prepared to MoE and FIU expectations.
MLRO Support
Money Laundering Reporting Officer staffing and ongoing operational support.
goAML & STR Filing
goAML portal registration and STR/SAR filing support with the UAE FIU.
Sanctions Screening
UN, OFAC, EU, UK and UAE local sanctions list integration with onboarding and ongoing monitoring.
Bank-Facing Readiness
Programme documentation packaged so UAE bank ongoing KYC and correspondent banking diligence go through cleanly.
Meet Our Specialists
Partner-led compliance practice — Vikas Dhingra leads AML alongside Avyanco's wider regulatory team.
Why Groups Choose Avyanco for AML
Three things that come up in every AML engagement.
Risk-Based Programmes
Programme design scaled to the actual risk profile — not boilerplate documentation that won't survive review.
End-to-End Delivery
Policy, MLRO, goAML, screening, monitoring, STR filing — handled by one team on one engagement letter.
Bank-Facing Readiness
Programme documentation built so UAE bank ongoing KYC and correspondent diligence go through.
What Clients Say
Recent feedback from entities Avyanco runs UAE AML work for.
We are very satisfied with Avyanco's support for Nanasu Realty — especially across AML compliance, accounting, and company setup.
Read more — Purushottam Mukkundi's review on GoogleP
Purushottam Mukkundi6 May 2026
I've used the services of Avyanco twice over the past 3 years for visa processing, and they have never failed to impress me.
Read more — Dominic Pinto's review on GoogleD
Dominic Pinto11 May 2026
I had an excellent experience with Avyanco Business Setup Consultancy for both my company formation and family dependent visa process in the UAE.
Read more — Eder Schaphauser Ziomek's review on GoogleE
Eder Schaphauser Ziomek29 April 2026
We had an excellent experience working with this company for our ADGM company setup in Abu Dhabi.
Read more — Nikhil Nadanga's review on GoogleN
Nikhil Nadanga25 May 2026
I have been dealing with Akshta for more than a year now and she has been very professional.
Read more — Sherif Ayub's review on GoogleS
Sherif Ayub24 May 2026
In so far as the emigration process can ever be made easy, Avyanco achieves exactly this.
Read more — Sheru George's review on GoogleS
Sheru George12 May 2026
UAE AML — Frequently Asked Questions
Common questions about UAE Anti-Money Laundering obligations.
What is a DNFBP?
DNFBP stands for Designated Non-Financial Business and Profession. The UAE Federal AML/CFT framework designates specific sectors as DNFBPs — including real estate brokers and agents, dealers in precious metals and stones, auditors, corporate service providers, lawyers and notaries. DNFBPs must register on goAML, implement a risk-based AML programme, appoint a compliance officer and file STRs / SARs as required.
What is the goAML portal?
goAML is the UAE Financial Intelligence Unit's online reporting system for AML/CFT obligations. DNFBPs, financial institutions and other obliged entities register on goAML and use it to file Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs) and other AML notifications. Registration is mandatory for in-scope entities.
Who is the supervisory authority for DNFBPs?
The UAE Ministry of Economy supervises most DNFBP sectors (real estate brokers and agents, dealers in precious metals and stones, auditors and accountants, and corporate/trust service providers), while the Ministry of Justice supervises lawyers, notaries and other independent legal professionals. DIFC and ADGM have their own AML regulators (DFSA and FSRA respectively) for entities licensed in those financial free zones. The specific supervisory authority depends on the entity's licence.
What is an MLRO and is it mandatory?
An MLRO is a Money Laundering Reporting Officer — the designated senior person responsible for the entity's AML programme, including STR/SAR filing. MLRO appointment is mandatory for obliged entities. The MLRO must have appropriate seniority, knowledge and independence to discharge the role.
What are the penalties for AML non-compliance?
UAE AML penalty schedules under the Federal AML/CFT framework run from financial penalties through to licence suspension or revocation. Penalties apply to failures around AML policy implementation, transaction monitoring, STR filing, sanctions screening, record-keeping and MLRO appointment. Avyanco's programme design is built to keep entities outside the penalty zone.
How does AML interact with UAE Corporate Tax?
AML KYC files inform source-of-funds disclosures, UBO disclosures inform related-party identification for Transfer Pricing, and ESR relevant-activity tests interact with AML obliged-entity status. Avyanco runs AML, Corporate Tax and ESR together so the cross-regime view stays consistent.
Sources & official references
Dubai International Financial Centre (DIFC) · Abu Dhabi Global Market (ADGM) · Federal Tax Authority (FTA) · UAE Ministry of Finance · UAE Ministry of Economy · Central Bank of the UAE
Verification & independence
Content prepared from publicly available UAE Ministry of Economy AML guidance, UAE Financial Intelligence Unit (FIU) goAML portal guidance and Federal Decree-Law No. 10 of 2025 on AML/CFT (in force 14 October 2025, replacing Decree-Law No. 20 of 2018), as of June 2026. Avyanco Business Consultancy LLC is independent of all UAE government authorities and not affiliated with any government agency.
AML obligations, DNFBP designations, supervisory authority requirements, STR thresholds and penalty schedules evolve. Always confirm the current obligations for your specific entity directly with the supervisory authority and a qualified compliance advisor before acting on any fact on this page.
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