Registration, reporting obligations and penalties under UAE AML/CFT/CPF laws and guidance.

What Is goAML? The UAE FIU’s Reporting Platform

The FIU has launched the goAML system for the purposes of facilitating the filing of applicable reports by all DNFBPs. DNFBPs are mandated to register on the goAML system by following the system registration guide and maintain their registration in an active status. The Compliance Officer of the company is required to register as the user of the system. goAML provides a secure link for each DNFBP to the FIU through their respective supervisory authorities. The system hosts processes for facilitating filing of applicable reports. The guidance documents for filing of STRs are posted on the dashboard of this system. All DNFBPs must register themselves immediately to confirm their readiness for filing of STRs/SARs and all other applicable reports.

Source: Guidelines for DNFBPs (March 2026), Section 10.1

The reports are received by the FIU and processed for any required further information or documents or for further action by Law Enforcement or Supervisory Authorities. The FIU maintains a record of these reports, performs a trend analysis to understand the prevailing trends in transactions and sectors or Institutions where possibility of ML/TF/PF exists and this trend analysis is shared with all the registered users of goAML through the system by means of a periodic trends and typologies report.

Source: Guidelines for DNFBPs (March 2026), Section 10.1

The UAE Financial Intelligence Unit (FIU)

An independent ‘Financial Intelligence Unit’ shall be established within the Central Bank and shall act independently. All Suspicious Transaction Reports and information related thereto shall be submitted thereto, exclusively, by all Financial Institutions, Designated Non-Financial Businesses and Professions and Virtual Asset Service Providers. The Unit shall undertake the study and analysis thereof, and shall refer the same to the Concerned Authorities either automatically or upon request.

Source: Federal Decree by Law No. (10) of 2025, Article (11)

The Unit shall operate as the national center for receiving Suspicious Transaction reports and other information relating to the Crime, analyzing such information, and disseminating the results of such analysis to Law Enforcement Authorities.

Source: Cabinet Resolution No. (134) of 2025, Article (44)(1)

The UAE FIU gains its legal mandate and powers primarily from the AML/CFT/CPF Law and Articles (44) to (47) of the Executive Regulations as an independent unit established to exclusively receive, analyse, and disseminate Suspicious Transaction / Activity Reports (STRs/SARs) from all Reporting Entities, including Financial Institutions (FIs), Designated Non-Financial Businesses and Professions (DNFBPs), and Virtual Asset Service Providers (VASPs), licenced or registered in the UAE.

Source: Guidelines for DNFBPs (March 2026), Section 10.1

What the FIU does with the reports it receives (Cabinet Resolution No. (134) of 2025, Article (46)):

• Receive reports from Financial Institutions, DNFBPs, and Virtual Asset Service Providers in accordance with the forms approved by the Unit, examine, analyze, and retain such reports in its database; (Art. 46(1))
• Request Financial Institutions, DNFBPs, Virtual Asset Service Providers, and Concerned Authorities to provide any additional information or documents relating to the reports and information received by the Unit. (Art. 46(2))
• Operational analysis, using available and obtainable information to identify specific targets such as persons, funds, or criminal networks, trace the course of specific activities or Transactions, and identify links between such targets, activities, or Transactions and potential criminal property; (Art. 46(3)(a))
• Strategic analysis using available and obtainable information, including data provided by the Concerned Authorities, to identify Crime trends and patterns; (Art. 46(3)(b))
• Provide Financial Institutions, DNFBPs, and Virtual Asset Service Providers with feedback on reports received by the Unit to enhance the effectiveness of Crime combating measures and the detection and reporting of Suspicious Transactions; (Art. 46(4))
• Cooperate and coordinate with the Supervisory Authority by referring the results of its analyses relating to the quality of reports received, in order to ensure compliance by Financial Institutions, DNFBPs, and Virtual Asset Service Providers with Crime combating procedures; (Art. 46(5))
• Use dedicated, secure, and protected channels to disseminate report-related data, analysis results, and other relevant information to Law Enforcement Authorities, where sufficient grounds exist to suspect a link to the Crime, for the purpose of taking the necessary actions in this regard; (Art. 46(6))

The FIU may request additional information from the reporting entity, Competent Authorities, or even from other DNFBPs which also have a business relationship with the subject of its analysis or investigation, through the Integrated Enquiries Management System (IEMS). Upon concluding its analysis or investigation, the FIU may disseminate information about the case to Law Enforcement Authorities or foreign FIUs, and may, at its own discretion, also provide feedback to the reporting entity in the form of instructions regarding required actions to be taken, or recommendations and guidance.

Source: Guidelines for DNFBPs (March 2026), Section 10.2

Is Your Brokerage Required to Register?

Designated Non-Financial Businesses and Professions (DNFBPs) shall include any person who carries out one or more of the following commercial or professional activities or businesses.

Real estate brokers and agents, when concluding transactions or settlements on behalf of their customers in relation to the purchase or sale of real estate.

Source: Cabinet Resolution No. (134) of 2025, Article (3)(2)

Real Estate Agents and Brokers, as defined under Article (3) of the AML-CFT Decision, are considered Designated Non-Financial Businesses and Professions (DNFBPs) when they conduct operations on behalf of customers related to the purchase or sale of real estate. These entities are subject to the UAE AML-CFT-CPF Law and AML-CFT-CPF Cabinet Resolution and are required to implement a comprehensive risk-based AML/CFT/CPF framework under the supervision of the Ministry of Economy and Tourism.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 2.1

No natural or legal person shall engage in any Financial Activities, Designated Non-Financial Businesses and Professions, Virtual Asset Service Providers, or Virtual Asset Service Provider activities without obtaining a license, registration, or enrolment from the Competent Authority or from the relevant Supervisory Authority, as the case may be.

Source: Federal Decree by Law No. (10) of 2025, Article (20)

DNFBPs are mandated to register on the goAML system by following the system registration guide and maintain their registration in an active status. The Compliance Officer of the company is required to register as the user of the system.

Source: Guidelines for DNFBPs (March 2026), Section 10.1

What You Must Report Once Registered

Reporting Suspicion: STRs and SARs

Where Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual Asset Service Providers suspect, or have reasonable grounds to suspect, that a Transaction or attempted Transaction, or funds, in whole or in part, constitute proceeds, are related to the Crime, or are intended to be used therein, regardless of their value, they shall, without invoking banking secrecy, professional secrecy, or contractual liability, comply with the following:

• Immediately and without delay notify the Unit by submitting Suspicious Transaction Reports, containing all available data and information relating to such Transaction or funds, and related parties, through the Unit’s electronic system or any other means approved thereby.
• Promptly respond to any request from the Unit for additional information.

Source: Cabinet Resolution No. (134) of 2025, Article (18)(1)

Where Financial Institutions, Designated Non-Financial Businesses and Professions, or Virtual Asset Service Providers suspect, or have reasonable grounds to suspect, that a Transaction or Funds, in whole or in part, represent Proceeds or are related to or intended to be used in the Crime, regardless of their value, they shall notify the Unit without delay and directly, by providing a detailed report containing all available data and information concerning such Transaction and the relevant parties, through the electronic system designated by the Unit or by any other approved means, and shall furnish any additional information requested by the Unit, without invoking confidentiality provisions.

Source: Federal Decree by Law No. (10) of 2025, Article (18)(1)

Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual Asset Service Providers shall establish indicators through which they are able to identify suspicion of a Crime for the purpose of submitting Suspicious Transaction Reports, and shall update such indicators on an ongoing basis in line with the development and diversification of methods used in the commission of a Crime, in compliance with instructions issued by the Supervisory Authority in this regard.

Source: Cabinet Resolution No. (134) of 2025, Article (17)

A suspicious transaction refers to any transaction, attempted transaction, or funds which a DNFBP has reasonable grounds to suspect as constituting (in whole or in part, and regardless of the amount or the timing) any of the following: The proceeds of crime (whether designated as a misdemeanour or felony, and whether committed within the State or in another country in which it is also a crime). Being related to the crimes of money laundering, the financing of terrorism, or proliferation financing. Being intended to be used in an activity related to such crimes.

Source: Guidelines for DNFBPs (March 2026), Section 10.3

Where suspicion arises, agents and brokers are required to escalate concerns internally and submit a Suspicious Transaction or Activity Report (STR/SAR) to the Financial Intelligence Unit (FIU), in accordance with legal requirements and without tipping off the customer.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 4.4

Failure to report a suspicious transaction without delay, whether intentionally or by gross negligence, is a federal crime in the UAE.

Source: Guidelines for DNFBPs (March 2026), Section 10

Reporting by Threshold: REARs

In addition to the obligation to submit Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) where reasonable grounds for suspicion arise, Real Estate Agents and Brokers are required to submit Real Estate Activity Reports (REARs) for transactions that meet the applicable monetary thresholds, regardless of whether suspicion is present.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 7

Real Estate Activity Reports are defined as a sector specific report for Real Estate Agents and Brokers to declare relevant transactions and activities. All real estate brokers and agents is required to file a REAR for:

• Purchase or Sale of freehold property / real estate where the method of payment includes cash and the amount is AED 55,000 or more; be it in a single payment or multiple payments.
• Purchase or Sale of Freehold property / real estate where the method of payment is a virtual asset for a portion or the entire property value.
• Purchase or Sale of Freehold property / real estate where the funds used to carry out the transaction were converted from or to a virtual asset for a portion or the entire property value.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 7.1

The obligation to submit REARs is not risk-dependent and must be fulfilled even when Customer Due Diligence measures have been satisfactorily completed and no red flags have been identified.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 7.1

When Real Estate Agents and Brokers are presented with a transaction that exceeds the REAR threshold and have reasonable grounds for suspicion, they must ensure that both, the threshold-based reporting and suspicions-based reporting obligations are met in accordance with their respective requirements.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 7.1

These obligations apply irrespective of whether a transaction is completed, attempted, or discontinued and must be implemented in a timely, accurate, and confidential manner.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 7

Confidentiality and Legal Protection

Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual Asset Service Providers, as well as their directors, officers, and employees shall be prohibited from disclosing, whether directly or indirectly, to the Customer or any other person that they have submitted or are about to submit a Suspicious Transaction Report, or any information or data related thereto, or that an investigation is being conducted in respect thereof.

Source: Cabinet Resolution No. (134) of 2025, Article (19)(1)

No criminal, civil, or administrative liability shall be incurred by the Supervisory Authorities, the Unit, the Law Enforcement Authorities, the Financial Institutions, the DNFBPs, the Virtual Asset Service Providers, or by the members of their Boards of Directors, employees, and legally authorized representatives, as a result of furnishing any of the required information or breaching any statutory, contractual, or administrative restriction imposed to ensure the confidentiality of information, even if they were not fully aware of the nature or actual occurrence of the Crime, unless it is proven that the reporting was made mala fide with the intent to harm others.

Source: Federal Decree by Law No. (10) of 2025, Article (37)(1)

Penalties for Non-Compliance

Administrative Sanctions

Without prejudice to any more severe administrative sanction prescribed under any other legislation, the Supervisory Authority may impose the following administrative penalties upon Financial Institutions, Designated Non-Financial Businesses and Professions, Virtual Asset Service Providers, and Non-Profit Organizations under its supervision, in the event of their violation of any provision of this Decree by Law, its Executive Regulations, or any other decisions issued thereby in connection therewith:

• Warning.
• An administrative fine of not less than ten thousand dirhams (AED 10,000) and not exceeding five million dirhams (AED 5,000,000) for each violation.
• Prohibiting the violator from engaging in the sector relevant to the violation for a period to be determined by the Supervisory Authority.
• Restricting the powers of board members, executive, supervisory, or managerial personnel, or owners proven responsible for the violation, including the appointment of a temporary supervisor.
• Suspending directors, board members, or executive or supervisory personnel proven responsible for the violation for a period to be determined by the Supervisory Authority or requesting their replacement.
• Suspending or restricting the activity or profession for a period to be determined by the Supervisory Authority.
• Revocation of the license.

Source: Federal Decree by Law No. (10) of 2025, Article (17)(1)

The Supervisory Authority may impose an incremental administrative fine in the event of recurrence of the same violation within a period not exceeding one year from the date of the prior administrative fine imposed therefor.

In all cases, the Supervisory Authority may publish the administrative penalties imposed by it through various media outlets.

Source: Federal Decree by Law No. (10) of 2025, Article (17)(3) and (4)

Real Estate Agents and Brokers who fail to implement adequate AML/CFT/CPF measures expose their firms and the wider sector to serious risks and may face supervisory actions, including financial penalties and other enforcement measures.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 2.2

Failure to submit REARs within the predefined parameters and timelines may undermine the effectiveness of the entity compliance framework and the UAE’s AML/CFT/CPF framework and expose Real Estate Agents and Brokers to regulatory action.

Source: Supplemental Guidance for Real Estate Agents & Brokers (2026), Section 7.1

Criminal Penalties

Failing to report a suspicion (violating Art. 18)

Whoever deliberately or through gross negligence violates the provisions of Article (18) hereof shall be punished by imprisonment and a fine of not less than one hundred thousand dirhams (AED 100,000) and not exceeding one million dirhams (AED 1,000,000), or by either of these two penalties.

Source: Federal Decree by Law No. (10) of 2025, Art. (28)

Tipping off

Any person who notifies or warns another person, or discloses any information related to Transactions under review concerning Suspicious Transactions, or reveals that the Competent Authorities are conducting inquiries or investigations in respect thereof, in contravention of Article (24) hereof, shall be punished by imprisonment and a fine of not less than fifty thousand dirhams (AED 50,000), or by either of these two penalties.

Source: Federal Decree by Law No. (10) of 2025, Art. (29)(1)

Operating without the required license, registration or enrolment

Any person who violates the provisions of Article (20) of this Decree by Law shall be punished by imprisonment and a fine of not less than two hundred thousand dirhams (AED 200,000) and not exceeding ten million dirhams (AED 10,000,000), or by either of these two penalties.

Source: Federal Decree by Law No. (10) of 2025, Art. (32)

Violating Targeted Financial Sanctions instructions

Imprisonment and a fine of not less than twenty thousand dirhams (AED 20,000), or by either of these two penalties.

Source: Federal Decree by Law No. (10) of 2025, Art. (33)

Legal person liability for the offences in Arts. (28), (29), (30), (32), (33), (34), (35)

A fine of not less than two hundred thousand dirhams (AED 200,000) and not exceeding ten million dirhams (AED 10,000,000).

Source: Federal Decree by Law No. (10) of 2025, Art. (27)(2)

Money laundering by a legal person

A fine of not less than five million dirhams (AED 5,000,000) and not exceeding one hundred million dirhams (AED 100,000,000), or an amount equivalent to the value of the Criminal Property involved; whichever is greater.

Source: Federal Decree by Law No. (10) of 2025, Art. (27)(1)

The AML/CFT/CPF Law provides for sanction against any person, including the DNFBP, or its managers and employees, who fail to perform, whether purposely or through gross negligence, their statutory obligation to report a suspicion of money laundering and related predicate offences or the financing of terrorism or of illegal organisations.

Source: Guidelines for DNFBPs (March 2026), Section 10

Regulatory References

1. Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing: Articles (11), (17), (18), (20), (27), (28), (29), (32), (33), (37).
2. Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025: Articles (3)(2), (17), (18), (19), (44) to (47).
3. Guidelines for Designated Non-Financial Businesses and Professions (March 2026): Section 5 (Overview of Applicable Sanctions), Section 10 (Suspicious Transaction Reporting), Sections 10.1 to 10.3.
4. Supplemental Guidance for Real Estate Agents & Brokers (2026): Sections 2.1, 2.2, 4.4, 7 and 7.1.
5. UAEFIU eServices

How AML360 Supports Your goAML Registration and Compliance Process

Registration on goAML is only one part of the AML/CFT/CPF compliance framework. AML360 handles it for you:

• Confirm your DNFBP status and registration obligations under current UAE AML law
• Advise on the right person in your firm to hold the MLRO/Compliance Officer role
• Prepare and review all required documents to MOET specification
• Manage both registration stages end-to-end, including MOET correspondence
• Assist with approvals and rejections from the MOET AML Department
• Keep your MLRO record up to date as your team changes, so MOET always has the right contact on file

Talk to AML360 today: +971 50 353 1635 · aml@aml360.io · www.aml360.io