DNFBPs in UAE

When most people think about anti-money laundering obligations, they think about banks. But in the UAE, as in every FATF member jurisdiction, a wide range of non-financial businesses and professions are also subject to AML law. These are known as DNFBPs: Designated Non-Financial Businesses and Professions.

Real estate agents, gold dealers, lawyers, accountants, auditors and company formation agents all fall within the DNFBP framework. For many, the obligations are just as demanding as those placed on regulated financial institutions, yet awareness and compliance rates have historically been lower, making the DNFBP sector a persistent focus for UAE regulators and FATF evaluators alike.

This guide explains what DNFBP means under UAE law, which sectors are covered, what the obligations are, and what happens when those obligations are not met.

1. What Does DNFBP Stand For? UAE Definition

DNFBP stands for Designated Non-Financial Business or Profession. The term originates from the FATF Recommendations, the international standards for combating money laundering and terrorist financing, which recognised that certain non-bank businesses are exposed to significant money laundering risk by virtue of the transactions they handle or the services they provide.

In the UAE, DNFBPs are defined and regulated under Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, and its implementing Cabinet Resolution No. 10 of 2019. The primary supervisory authority for most DNFBP sectors is the Ministry of Economy (MoE), which operates the UAE’s DNFBP compliance and registration framework through its Anti-Money Laundering Department.

2. Full List of DNFBP Sectors in UAE

The following sectors are designated as DNFBPs under UAE AML legislation. The table below also identifies the relevant supervisor and the primary trigger activity that brings each sector within the AML framework.

It is important to note that DNFBP obligations do not apply to every activity a business conducts, they apply when the business carries out specific trigger activities. A law firm, for example, is not subject to AML obligations when it provides litigation advice, but it is when it handles client funds or assists in the formation of a company.

3. Real Estate Agents & Brokers as DNFBPs

Real estate is consistently identified as one of the highest-risk DNFBP sectors in the UAE. The combination of high transaction values, frequent use of corporate buyers, significant international capital flows and historically limited transparency has made UAE property, particularly in Dubai and Abu Dhabi, an attractive vehicle for money laundering at the integration stage of the laundering cycle.

Real estate agents and brokers are subject to UAE AML obligations when they assist a client in buying or selling property. The obligation is triggered by the agency relationship, not by the transaction value, meaning that all property transactions, not just those above a certain threshold, are in scope.

Key Risk Indicators in Real Estate

• Cash payments or third-party payments for reservation fees or deposits where the payer has no apparent connection to the buyer

• Buyers using corporate vehicles, particularly offshore SPVs or holding companies, with no clear commercial rationale

• Requests to structure the transaction in a way that obscures the identity of the ultimate purchaser

• Rapid resale of a property after purchase, particularly at a loss or at a significant premium inconsistent with market conditions

• Buyers who show little interest in the property itself but are focused on the speed or structure of the transaction

RERA (Real Estate Regulatory Agency) in Dubai and the relevant authorities in Abu Dhabi work alongside the Ministry of Economy to supervise the real estate DNFBP sector. Brokers registered with RERA are required to comply with RERA’s own AML guidelines in addition to the MoE framework.

4. Dealers in Precious Metals & Stones (DPMS)

Dealers in precious metals and stones include businesses that buy or sell gold, silver, platinum, diamonds, gemstones and luxury jewellery. The UAE, and Dubai in particular, is a global hub for the gold and diamond trade, which has historically attracted significant financial crime risk.

The AML trigger for DPMS businesses is cash. Under UAE law, DPMS dealers are subject to full AML obligations, including customer due diligence, transaction monitoring and STR filing, when they conduct any cash transaction of AED 55,000 or more, whether in a single transaction or a series of linked transactions.

Why DPMS Is High Risk

• Gold and precious stones are highly portable, easily converted to cash in any jurisdiction, and difficult to trace once melted or recut

• The global gold market is fragmented, with significant volumes traded through informal channels and small dealers who may have limited compliance capacity

• Trade-based money laundering schemes have used gold exports from the UAE to move value across borders under the cover of legitimate commodity trade

• The anonymity historically available in cash-for-gold transactions made the sector attractive to placement-stage laundering

5. Lawyers, Notaries & Accountants

Legal and accounting professionals occupy a uniquely sensitive position in the DNFBP framework. They are often the architects of the corporate structures, financial arrangements and transactions that money launderers use, sometimes unknowingly, sometimes not.

Under UAE AML law, lawyers and legal professionals are subject to AML obligations when they carry out specific activities on behalf of a client. These are defined activities, not general legal practice:

• Buying or selling real estate

• Managing client money, securities or other assets

• Managing bank, savings or securities accounts

• Organising contributions for the creation, operation or management of a company

• Creating, operating or managing legal persons or arrangements (trusts, foundations, holding structures)

• Buying or selling business entities

Auditors, external accountants and tax advisors are subject to equivalent obligations when they provide similar services, particularly financial management, business formation, or assistance with company acquisitions.

Professional Privilege and AML Obligations

A common question from legal professionals is whether legal professional privilege exempts them from AML reporting obligations. Under UAE law, privilege does not exempt a lawyer from filing a suspicious transaction report where the information on which the report is based was obtained outside of a privileged legal consultation. The precise boundaries of privilege in the UAE AML context are nuanced, and legal professionals are advised to seek specialist guidance.

6. Corporate Service Providers (CSPs) – Trust Companies & Company Formation

Corporate service providers, also referred to as trust and company service providers (TCSPs), are businesses that offer company formation, registered office, directorship, nominee shareholder or trust administration services to third parties. In the UAE, this sector includes business centres, company formation agents, registered agents in free zones and corporate secretarial firms.

CSPs are among the highest-risk DNFBP categories globally. The services they provide – forming legal entities, providing nominee directors or shareholders, managing trust structures are precisely the tools used in the layering stage of money laundering to obscure beneficial ownership and create corporate distance between a criminal and their assets.

AML Obligations for CSPs

A CSP is subject to UAE AML obligations when it provides any of the following services for a client:

• Acting as a formation agent for legal persons (companies, foundations, partnerships)

• Acting as or arranging for another person to act as a director or secretary of a company, a partner in a partnership, or a similar role in relation to other legal persons

• Providing a registered office, business address or accommodation address

• Acting as or arranging for another person to act as a trustee of an express trust or a similar legal arrangement

• Acting as a nominee shareholder for another person

Given the UAE’s position as a major free zone hub with over 40 free zones offering company formation services, the CSP sector is large, diverse and variable in compliance maturity. Regulators have identified free zone CSPs as a particular area of focus in recent enforcement cycles.

7. DNFBP AML Obligations: Registration, CDD, STR Filing

Regardless of which DNFBP sector a business operates in, the core AML obligations under UAE law are consistent. They cover five main areas:

1. Registration

All DNFBPs supervised by the Ministry of Economy must register on the MoE’s DNFBP registration platform (accessible at the MoE portal). Registration is a prerequisite for operating as a DNFBP, it is not optional and does not depend on transaction volumes. Failure to register is itself a violation of UAE AML law.

2. Business Risk Assessment

DNFBPs must document and maintain a written assessment of the money laundering and terrorist financing risks specific to their business, client base, geographic exposure and service types. This Business Risk Assessment (BRA) must be kept up to date and made available to supervisors on request.

3. AML Policies and a Compliance Officer

Every DNFBP must have written AML/CFT policies and procedures appropriate to its risk profile and must appoint a named Compliance Officer responsible for implementing the AML programme, overseeing CDD, managing STR filings and providing staff training.

4. Customer Due Diligence (CDD)

DNFBPs must conduct customer due diligence on all clients at onboarding and on a risk-sensitive ongoing basis. CDD includes:

• Identifying and verifying the customer’s identity using reliable, independent documents

• Identifying and verifying the ultimate beneficial owner (UBO) of any corporate customer (the natural person(s) who ultimately own or control the entity)

• Understanding the nature and purpose of the business relationship

• Applying enhanced due diligence (EDD) for high-risk customers, politically exposed persons (PEPs), and customers from high-risk jurisdictions

• Conducting ongoing monitoring of the business relationship and transactions

Where a DNFBP cannot complete CDD because a customer refuses to provide documents or the UBO cannot be identified, the business must not proceed with the transaction and must consider filing an STR.

5. Suspicious Transaction Reporting (STR)

Where a DNFBP knows, suspects or has reasonable grounds to suspect that a transaction or attempted transaction involves the proceeds of crime or is connected to terrorist financing, it must file a Suspicious Transaction Report (STR) with the UAE Financial Intelligence Unit (UAEFIU) through the goAML platform. The report must be filed promptly without delay and the customer must not be informed that a report has been made (tipping-off prohibition).

8. Penalties for Non-Compliance

The UAE AML enforcement regime for DNFBPs has become significantly more active since 2020. The Ministry of Economy has conducted hundreds of inspections across DNFBP sectors and has issued administrative sanctions against non-compliant businesses in the real estate, gold and CSP sectors. The following table summarises the key penalty categories:

Beyond financial penalties, the reputational consequences of an AML enforcement action, particularly a public sanction or licence suspension, can be severe and lasting. The MoE publishes enforcement actions, and regulatory findings can affect a business’s ability to maintain banking relationships, renew licences and retain clients.