Anti-Money Laundering (AML) and Compliance Audit Process in Dubai, UAE

The United Arab Emirates (UAE) is seriously implementing AML (Anti Money Laundering) and UBO (Beneficial Owner) regulations in order to increase financial transparency and ensure compliance with international standards. In this context, the UAE Cabinet's Decision No. 10 of 2019 and Decision No. 109 of 2023 set out the rules that companies must comply with. The aim is to check whether companies are fulfilling their obligations to prevent money laundering and terrorist financing.

What are the required documents for the Anti-Money Laundering (AML) and Compliance Audit Process in Dubai, UAE?
Companies must prepare the following documents in PDF format:

Articles of Association and amendments
Trade License
Company address document (lease agreement, etc.)
Partners' register
UBO (Ultimate Beneficial Owner) register
Passports, residence permits, visas, and Emirates IDs of all members
UBO Declaration
Nominee agreements (if any)
Contact information of authorized persons
Audited financial statements
Bank statements for the last 6 months
Proof of activities such as invoices, orders, and contracts
Company ownership structure
Purpose of establishment – brief description
Dubai AML Regulatory Guidelines and Enforcement Authorities
AML regulations in the UAE are not limited to federal law. Various financial and regional authorities operating in the country issue sector-specific guidelines and circulars to detail the implementation. The main regulatory bodies are as follows:

Central Bank of the UAE (CBUAE): Has direct authority over banks, currency exchange offices, and financial institutions.

Dubai Financial Services Authority (DFSA): Oversees the AML compliance processes of financial institutions located within the Dubai International Financial Centre (DIFC).

Abu Dhabi Global Market (ADGM) – Financial Services Regulatory Authority (FSRA): Applies guidelines and controls applicable to all licensed firms operating in the ADGM region.

These authorities ensure sectoral compliance by issuing guidance documents, risk assessment reports, and implementation circulars related to AML/CFT regulations.

Things to Consider for the Anti-Money Laundering (AML) and Compliance Audit Process in Dubai, UAE
1. Consistency of Documents: It is important that all documents are up-to-date, accurate, and contain information that does not contradict each other. In particular, there should be consistency between the ownership structure, UBO records, and bank transactions.

2. UBO Definition: A UBO is an individual who directly or indirectly holds a 25% or higher stake in the company. These individuals must be clearly disclosed.

3. Proof of Activity: If documents proving that the company is actually operating (invoices, contracts, etc.) are not submitted, there is a risk that the company may be considered a “shell company” (a company that is not operating).

4. Authorized Person Information: It is very important that the contact information of the person who will upload the documents and follow up on the process is accurate. The relevant audit team will communicate directly with this person.

For every company operating in the UAE, full compliance with AML and UBO regulations is no longer just a legal obligation but also a critical necessity in terms of reputation and sustainability. Prioritizing this process is the most effective way to protect your company from criminal penalties and reputational damage.

World Company Setup's Expertise and How We Can Assist You
As the leading AML (Anti-Money Laundering) consulting firm in the United Arab Emirates, World Company Setup guides businesses operating in Dubai in creating a transparent, ethical, and sustainable business environment.

We offer comprehensive audit and consulting services to protect your financial structure from illegal activities such as fraud, money laundering, and suspicious transactions.

Expert Audit and Compliance Analysis

The experienced AML experts at World Company Setup Auditing thoroughly review your company's accounting records, transaction movements, and ledgers to proactively identify potential risks.

During this process, we focus on:

Suspicious transactions,
Unusual financial movements,
Inadequate customer due diligence (CDD/KYC) practices

The UAE's AML Legal Framework and Competent Authorities
The United Arab Emirates (UAE) has demonstrated a strong and comprehensive stance in combating money laundering (ML) and terrorist financing (FT). The country has a robust Anti-Money Laundering (AML) legal framework that is structured to be compliant with both national and international standards. This framework clearly defines the obligations of entities across different sectors and is enforced through various regulatory authorities.

Key Legal Regulation: Federal Decree No. 20 (2018)

Federal Decree No. 20, which came into force in 2018, forms the main legal basis for AML/CFT in the UAE. With this law:
The obligation of companies to know their customers (Customer Due Diligence - CDD) has been clearly defined.
The reporting of suspicious transactions (STR) has become mandatory.
Every reporting entity is required to appoint an AML Compliance Officer (MLRO).
Administrative and criminal penalties for non-compliance with compliance obligations have been established.
This law is binding on all financial institutions, certain commercial enterprises, and companies in free zones.

AML Compliance is a Strategic Necessity
For every company operating in the United Arab Emirates, compliance with AML regulations is not only a legal requirement but also a fundamental condition for being a reputable and sustainable player in the international investment environment.

At World Company Setup, we provide professional support for all the necessary steps to ensure your company is fully compliant with the UAE AML/CFT framework. World Company Setup can coordinate the entire process on your behalf. We are with you every step of the way, including the preparation, review, and submission of documents. Whether you are setting up a new entity or maintaining an existing one, managing compliance processes can be complex. However, with the right guidance, this process is not just a burden but an opportunity for trust and sustainability for your company.

UAE Dubai (AML) Anti-Money Laundering and Compliance Audit Process Frequently Asked Questions 
What is AML?
Anti-Money Laundering (AML) refers to regulations aimed at preventing illicitly obtained funds from entering the financial system.

Why is the UBO declaration important?
Identifying the real persons behind the company is mandatory for transparency and security. Concealed ownership structures can result in serious penalties.

Does the process take a long time?
If the documents are ready, it can be completed in a few days. If there are any deficiencies, the process may take longer.