Telephone Numbers
Telephone Numbers
For detailed information +90 542 381 3868'Call.
In the real estate sector, AML compliance is not limited to simply registering with goAML. Companies in Dubai that engage in brokerage, buying and selling, or project marketing must monitor transaction-based reporting thresholds, verify the identity and source of funds for both buyers and sellers, and retain these records for at least five years. In particular, real estate payments made in cash of 55,000 AED or more, as well as those made with crypto assets, are among the transaction types that must be reported separately to the Financial Intelligence Unit.
The most common mistake encountered in practice is when a company merely registers with the system but fails to establish an internal compliance program. During audits, in addition to the registration itself, a written AML policy, a designated compliance officer, staff training records, and a risk assessment file are also reviewed. For this reason, real estate companies must plan their application in conjunction with an end-to-end compliance infrastructure.
Real estate companies operating in Dubai are among the most frequently monitored sectors in terms of AML regulations due to high-value transactions and international client portfolios. In property sales, purchases, and leasing processes, there are obligations related to Know Your Customer (KYC), transaction monitoring, and suspicious transaction reporting.
Within the scope of AML compliance, real estate companies are required to establish goAML system registration, internal AML policies, risk-based customer due diligence procedures, and regular reporting mechanisms. In particular, off-plan sales, high-value cash transactions, and transactions involving foreign investors are considered higher risk categories from an AML perspective.
Companies engaged in the trade of gold, diamonds, and other precious metals and stones fall under the DNFBP category according to UAE regulations and are considered high-risk sectors. These businesses are required to ensure transaction traceability and implement a strong compliance framework to mitigate money laundering risks.
In this context, companies must implement customer identity verification procedures, maintain transaction records, submit suspicious transaction reports (STR), and formalize written AML compliance policies. Cash-intensive operations and international trade activities are subject to enhanced regulatory scrutiny.
Firms providing accounting, financial advisory, and audit services carry significant AML responsibilities as they directly influence clients' financial operations. In the UAE, companies operating in this field are legally required to complete AML registration and establish a formal compliance program.
This process includes customer risk classification, financial transaction analysis, internal control mechanisms, and the appointment of a compliance officer. In addition, regular training and internal audit procedures are essential to ensure the sustainability of AML compliance.
Corporate service providers involved in company formation, corporate structuring, and trust or foundation-related activities are directly subject to AML regulations, as they establish and manage legal entities on behalf of clients. These firms are required to identify Ultimate Beneficial Owners (UBO) and implement comprehensive compliance procedures.
Improper client onboarding processes or incomplete documentation checks may lead to serious administrative penalties and licensing risks. Therefore, establishing a comprehensive compliance infrastructure alongside the AML application process is essential.
goAML is the official AML reporting and suspicious transaction monitoring system used by the UAE Financial Intelligence Unit (FIU). Registration in the goAML system and reporting through this platform are mandatory for most companies falling under the DNFBP category.
Through this system, companies submit Suspicious Transaction Reports (STR), Suspicious Activity Reports (SAR), and other compliance-related notifications to the relevant authorities. Without goAML registration, it is not possible to fully meet AML regulatory obligations.
goAML registration is completed in a two-stage system and, with the correct set of documents, typically takes a few business days:
1. Pre-registration (SACM): Pre-registration is completed on the Financial Intelligence Unit's secure access portal using the company and authorised-person details; once approved, an access code is sent by e-mail.
2. Document upload: The trade licence, copies of the authorised person's passport and Emirates ID, and a signed authorisation letter are uploaded to the system.
3. goAML entity registration: Using the access code, a "reporting entity" account is created on the goAML platform and the company's supervisory authority is selected.
4. Appointment of a compliance officer: An AML compliance officer (MLRO) is designated within the company and authorised in the system.
5. Building the compliance framework: A written AML policy, customer acceptance procedures and a company-wide risk assessment are prepared.
6. Ongoing reporting: Suspicious transaction reports (STR) and suspicious activity reports (SAR) are filed through this platform for as long as the business remains active.
Data-entry errors on the application screens and missing authorisation documents are the most common reasons for rejected registrations; we recommend a pre-submission document review to complete the process in a single attempt.
In the UAE, breaches of AML obligations can result in administrative fines, restrictions on business activities and even licence revocation. For violations such as failure to register, failure to appoint a compliance officer or failure to file suspicious transaction reports, fines start from AED 50,000 and can reach several million dirhams depending on the nature of the breach. A risk just as significant as the fines themselves is that violations recorded in a company's audit history can complicate banking relationships and licence renewals. Contact our advisors for the current penalty schedule and a risk analysis tailored to your company.
A real estate brokerage company we recently advised had worked with a different consultancy firm during its incorporation, yet was never informed that goAML registration was mandatory for its scope of activity. The company only became aware of this obligation when its bank requested a goAML registration number during the account-opening and compliance checks.
In our initial review, we determined that the company fell within the DNFBP scope. By preparing the required documents, completing the compliance checks and managing the official application steps, we finalised the goAML registration within approximately 2 days. As a result, the registration details requested by the bank were submitted on time, the process moved forward without delay and potential administrative penalty risks were avoided.
One of the most common issues we have encountered in our AML compliance work in recent years is that companies falling within the DNFBP scope are not adequately informed about the goAML requirement at the incorporation stage. Many businesses only realise this obligation when a bank, a supervisory body or another official authority requests their goAML registration number. Yet analysing the scope of activity correctly at the incorporation stage and fulfilling AML obligations on time helps prevent administrative fines, delays in banking processes and compliance risks.
AML application processes in Dubai and across the UAE form a comprehensive procedure covering regulatory analysis, DNFBP scope determination, goAML registration, risk assessment documentation, know-your-customer (KYC) procedures and the preparation of internal compliance policies. As the obligations vary depending on the sector of activity, building a compliance strategy tailored to the business — rather than following a standard application method — is of great importance. With AML consultancy delivered in integration with our Dubai tax consultancy services, official applications are prepared in full, compliance processes are managed effectively and potential administrative penalty risks are minimised.
Real estate companies, accounting and auditing firms, financial advisory companies and businesses trading in precious metals and precious stones operating across all emirates of the UAE — Dubai in particular — as well as organisations active in company formation in Dubai and corporate service provision (Company Formation & Trust Services), are subject to AML obligations under the DNFBP regulations. Within this scope, completing goAML registration, establishing risk-based compliance programmes and implementing internal control mechanisms in line with the applicable UAE regulations is a legal requirement for these businesses.
DNFBP (Designated Non-Financial Businesses and Professions) refers to “certain non-financial businesses and professions” that, although not banks, are subject to AML regulations because they pose a money laundering risk. In the UAE, this scope includes four main groups: real estate agents and brokers; traders in precious metals and stones such as gold and diamonds; independent accounting and auditing firms; and company formation and corporate service providers.
If your business activity falls under one of these groups as listed on your trade license, you may be subject to registration requirements even if you are not actually conducting that business. Scope determination is based on license activity codes; an incorrect self-assessment can lead to both unnecessary registration costs and, conversely, administrative penalties. If you are unsure, please contact us for a free preliminary review of your license.
No. The registration requirement applies to sectors covered by the DNFBP (real estate, trade in precious metals and stones, accounting and auditing, and corporate service providers) as well as financial institutions. The scope is determined based on the activity codes listed on the business license.
If all documents are complete, pre-registration and institutional registration are typically completed within a few business days. A missing authorization letter or incorrect information are the most common reasons for delays in the process.
The basic set of documents consists of a valid business license, copies of the authorized person’s passport and Emirates ID, a letter of authorization issued by the company’s signatory, and the company’s contact information. Additional documents may be required depending on the industry.
Yes. Companies engaged in DNFBP activities are subject to AML obligations regardless of whether they operate on the mainland or in a free zone; only the applicable regulatory authority may differ.
Yes. Registration is the first step; a written AML policy, the appointment of a compliance officer, know-your-customer (KYC) procedures, staff training, record retention, and the reporting of suspicious transactions are ongoing obligations.
+90 542 381 3868
+971 58 5204103