Frequently Asked Questions on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations (the “AML-CFT Law” or “the Law”)

The Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD) under the Central bank of UAE implements and administers the UAE anti-money laundering laws and regulations and AML/CFT Guidelines 2021.

Federal Decree No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations along with implementing Cabinet Decision No. [10] of 2019 is the guiding legislation for AML/CFT framework in UAE.

Financial Institutions and Designated Non-Financial Businesses and Professions are required to comply with the AML/CFT Regulations.

Following categories of businesses are included in this category:
 Brokers & Real Estate Agents
 Dealers in Precious Stones & Metals
 Independent Legal Professionals & Accountants
 Providers of Corporate Service and Trusts

Transactions with monetary value equal to or exceeding AED 55,000 (single/related) requires entities to carry out appropriate Customer Due Diligence measures and make appropriate reporting as required by the regulation.

Sanction lists label certain individuals, entities and countries with the intention of prohibiting business transactions with such individuals, entities, and countries because of their association with terrorism activities, violation of human rights, narcotics trading etc. AML/CFT Law requires every entity registered in GoAML to subscribe to its Local list and UN Security Council’s List .

As per the AML/CFT Law, Financial Institutions and DNFBPs should appoint a Compliance officer in house or outsourced with adequate expertise and knowledge who can implement appropriate policies and procedures and make periodic assessments and reports in relation to entity’s compliance with the AML/CFT law.

MLRO Report is the report submitted by the Money Laundering Officer/Compliance Officer highlighting the gap between existing AML /CFT compliance in the organization  with the ideal framework . Such report should be submitted semi-annually both to the senior management and relevant supervisory authority.

There are both temporary and unalterable punishments prescribed in the law ranging from temporary imprisonment to imprisonment for not exceeding 10years and fines ranging from AED 100,000 (one hundred thousand) to AED  50,000,000 (fifty million).