goAML registration and AML obligations

The UAE's anti-money-laundering framework places obligations not only on financial institutions but on Designated Non-Financial Businesses and Professions — real estate agents and brokers, dealers in precious metals and stones, auditors and accountants, lawyers and notaries in defined circumstances, and company service providers. Those businesses must register on the goAML portal, appoint a compliance officer, conduct customer due diligence, screen against sanctions lists, keep records, and file suspicious transaction and suspicious activity reports.

This is where compliance obligation and business reality diverge most sharply. A four-person real estate brokerage has the same categorical obligations as a large institution: a named compliance officer, a written AML policy, risk-rated customer due diligence, ongoing sanctions screening, and the judgement to recognise and report a suspicious transaction. Most do not have any of it, and the penalties for failure — including failure to register on goAML at all — are substantial. It is the most commonly overlooked regulatory obligation among small UAE businesses in the affected sectors.

Thresholds and deadlines

Who

Real estate brokers, precious metals dealers, auditors, lawyers, corporate service providers

Registration

The goAML portal — a standalone obligation

Compliance officer

Must be appointed and named

Due diligence

Risk-rated CDD on customers, with enhanced measures where indicated

Screening

Against sanctions and terrorist financing lists

Reporting

Suspicious transaction and suspicious activity reports

1. Establish whether the business is a DNFBPThe categories are defined. Real estate and precious metals are the two most commonly caught and least commonly compliant.
2. Register on goAMLFailure to register is itself a penalised breach, separate from any reporting failure.
3. Appoint and name a compliance officerWith actual authority and actual time, not a title added to someone's existing role.
4. Write and implement the AML policyRisk assessment, customer due diligence procedures, screening, record keeping and escalation.
5. Train the people who meet customersThe obligation to recognise a suspicious transaction sits with the person in front of the customer.

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