Dubai AML and compliance services.
Anti-money laundering obligations do not have the same scope for every company. We identify the registration and reporting obligations that apply to your company and follow up the related processes.
- Ultimate beneficial owner register for every company
- goAML only for certain activities
- Regulatory compliance from a single team
Dubai AML and Corporate Compliance Obligations.
In the United Arab Emirates, the compliance obligations of companies differ according to their field of activity, corporate structure and the regulations to which they are subject. In addition to general corporate registration obligations, additional AML controls and reporting requirements apply to businesses operating in certain sectors.
Corporate registration and notification obligations
- Ultimate Beneficial Owner (UBO) Registers: Determining the ultimate ownership and control structure, and keeping and updating the required records.
- Shareholder and Manager Details: Keeping shareholder, management and authorised signatory records up to date, and notifying the relevant authorities of any necessary changes.
- Corporate Documentation: Presenting company information, activity documents and related corporate records in a verifiable form when required.
Additional compliance and control requirements
- Real estate brokerage
- Precious metals and stones trading
- Accounting and audit services
- Corporate service provision
- Certain legal and advisory services
Requirements that may apply to the obligated entities concerned
- goAML Registration: Registration processes for the relevant FIU registration and reporting system.
- Know Your Customer (KYC/CDD): Customer identity verification, identification of beneficial owners and risk-based reviews.
- Sanctions and PEP Screening: Assessing customers and related persons against applicable sanctions lists and risk criteria.
- Suspicious Transaction Reporting (STR/SAR): Assessing suspicious transactions and activities and reporting them to the competent authority when the conditions for notification arise.
- AML Risk Assessment: Analysing the business's activity, customer and transaction risks.
- Internal Policy and Compliance Management: Written procedures, internal controls, compliance officer arrangements where required, and staff training.
The scope of the obligations is determined by the company's activities, licence, regulatory authority and the legislation in force. Different requirements may apply even to businesses in the same sector.
Let Us Assess Your Company's Compliance ObligationsOur AML and Compliance Services.
We assess the AML and regulatory obligations that apply to your business, and provide professional support in establishing and implementing the necessary policy, procedure, record-keeping and control processes.
Our service scope
- AML Compliance Assessment
- AML Risk Assessment
- AML Policies and Procedures
- KYC / CDD / EDD
- Sanctions and PEP Screening
- goAML Registration and Support
- UBO and Corporate Compliance
- AML Training and Periodic Review
Outside our scope
- Legal representation, litigation and defence services
- Decisions and responsibility regarding suspicious transaction reporting
- Banks' independent account-opening and risk assessment decisions
- The client's own legal obligations and any sanctions arising from their breach
Obligation Headings.
Each heading sets out the scope of the obligation, when it applies and the support we provide.
Ultimate Beneficial Owner (UBO) Registration and NotificationsDetermining, recording and keeping up to date the company's ultimate ownership and control structure.By company type
- Obligation
- Companies subject to the relevant legislation are required to examine their direct or indirect ownership and control structure, identify their ultimate beneficial owners (UBOs) and keep the necessary records. In identifying beneficial owners, control methods other than the ownership percentage are also taken into account.
- When it applies
- At company formation, when a change occurs in the ownership or control structure, and in situations where the relevant legislation requires the records to be updated.
- Support from Ortac Global
- We provide support in examining the company's ownership and control structure, identifying beneficial owner information, preparing supporting documents and carrying out the related registration and notification processes.
Updating Shareholder and Manager RecordsKeeping the company's shareholder, management and authorised signatory details accurate, current and consistent with official records.Corporate compliance
- Obligation
- Companies are required to keep their records of ownership structure, managers and authorised signatories in line with the relevant legislation and to notify the competent authorities of any necessary changes. It is important that corporate records are consistent with the trade licence and other official documents.
- When it applies
- At company formation and whenever there is a change in the ownership structure, managers, authorised signatories or registered company details, within the applicable notification periods.
- Support from Ortac Global
- Within our service scope, we provide support in preparing the documents required for changes in ownership and management, coordinating official applications and notifications, and updating company records.
Banking KYC and Compliance ProcessesThe information and documents banks request about the company, its ownership structure, activities and sources of funds.Banking requirements
- Obligation
- As part of their customer due diligence and risk assessment processes, banks may request information and documents verifying the company's ownership and control structure, commercial activities, transaction profile and sources of funds.
- When it applies
- When a bank account is opened, during periodic customer reviews, and when there are significant changes in the company's activity, ownership or transaction profile.
- Support from Ortac Global
- We provide support in preparing the corporate information and documents the bank requests, organising the KYC file and coordinating the application or update process. The decision on account opening and customer acceptance rests with the bank concerned.
goAML Registration and ReportingAccess to the FIU reporting system, and the related processes, for entities with reporting obligations under AML legislation.Obligated entities
- Obligation
- Entities subject to the relevant AML regulations are required to register with the goAML system, define their authorised users and be able to make the necessary reports in accordance with the legislation.
- When it applies
- When the relevant activity and regulatory obligations begin, within the applicable registration periods. If registration details or authorised users change, the necessary updates are made.
- Support from Ortac Global
- We provide technical and operational support for the goAML registration process, the preparation of the necessary corporate documents, user authorisations and use of the system. Reporting obligations and decision-making authority remain with the obligated entity concerned.
Customer Due Diligence (CDD/EDD) and Sanctions ScreeningVerifying customer identity, identifying beneficial owners and establishing sanctions and risk screening processes.AML-obligated entities
- Obligation
- The AML-obligated entities concerned are required to know their customers and beneficial owners, assess the purpose of the business relationship, carry out the necessary reviews according to the level of risk, and perform controls in line with applicable sanctions obligations.
- When it applies
- When a business relationship is established, during transactions provided for in the relevant legislation, and on a risk basis for as long as the customer relationship continues. Additional review may be required in the event of significant changes or when suspicion arises.
- Support from Ortac Global
- We provide support in establishing customer due diligence procedures, risk classification methods, sanctions and PEP screening processes and the record-keeping system. Where necessary, we help structure enhanced due diligence (EDD) processes.
Suspicious Transaction and Activity Reporting (STR/SAR)Reporting transactions and activities that give rise to suspicion of money laundering or terrorist financing to the competent authority.AML-obligated entities
- Obligation
- Entities subject to AML legislation are required to detect and assess suspicious transactions or activities and, when the conditions for notification arise, to make the necessary report to the UAE Financial Intelligence Unit (FIU) through the goAML system.
- When it applies
- Without delay, in accordance with the periods and procedures set out in the legislation, once the situation giving rise to suspicion has been identified and assessed and the reporting obligation has arisen.
- Support from Ortac Global
- We provide support in establishing internal procedures for detecting suspicious transactions and activities, and assessment and escalation mechanisms. We offer operational guidance on the reporting process. Reporting decisions and legal responsibilities remain with the authorised persons of the obligated entity.
Sector-Specific Transaction Reports (DPMSR / REAR)Special reports on transactions meeting certain conditions in the precious metals and stones trade and in the real estate sector.Certain sectors and transactions
- Obligation
- For obligated entities trading in precious metals and stones, DPMSR reports linked to certain cash transaction thresholds may arise; in the real estate sector, REAR reports linked to defined payment types and transaction conditions may arise. These reports differ from suspicious transaction reports and are assessed against criteria specific to the sector concerned.
- When it applies
- When a transaction meeting the relevant reporting conditions takes place, within the notification periods in force.
- Support from Ortac Global
- We assess which specific reporting obligations may apply according to the business's field of activity and the characteristics of its transactions, and provide support in establishing the necessary information, documents and reporting processes.
AML Risk Assessment and Internal Control PoliciesAssessing the business's money laundering and terrorist financing risks and establishing suitable control mechanisms.AML-obligated entities
- Obligation
- AML-obligated entities are required to assess the risks arising from their activities, customers, countries, products, services and transaction channels, and to establish written policies, procedures and internal control mechanisms appropriate to the level of risk. Under applicable regulations, appointing a qualified compliance officer and providing the necessary training are also part of this structure.
- When it applies
- Established when the relevant AML obligations begin; updated when activities, risk profile or legislation change, and at the necessary periodic reviews.
- Support from Ortac Global
- We provide support in preparing an AML risk assessment, policies and procedures suited to the business's activity and risk profile, and in structuring internal control, customer review and compliance processes.
Economic Substance Regulations (ESR): Obligations for Past PeriodsESR notification and reporting obligations have been removed for financial years ending after 31 December 2022. Responsibilities relating to earlier periods may continue.Past periods
- Obligation
- Under Cabinet Resolution No. 98 of 2024, the ESR notification and reporting requirement has been removed for financial years ending after 31 December 2022. However, companies that fell within the scope of ESR in earlier financial years may continue to have past-period notification, reporting and related compliance obligations.
- When it applies
- Past-period obligations are assessed for financial years that ended on or before 31 December 2022 and fell within the scope of ESR. Requests for information, correction or review from the relevant authorities are also taken into account.
- Support from Ortac Global
- We assess your company's past-period ESR obligations, its notification and reporting status and any gaps. Within our service scope, we provide support with the necessary document preparation, corrections and processes to be carried out with the relevant authorities.
Customer Due Diligence and AML Control Process.
For AML-obligated businesses, we provide support in establishing customer due diligence, identity verification, sanctions screening and risk assessment processes. Controls are carried out according to the customer's risk profile and the relevant legislation.
Customer Information
The necessary information on the customer's identity, activities and the purpose of the business relationship is obtained.
Identity and UBO
Identity and corporate documents are verified; beneficial owners are identified.
Sanctions Screening
The customer and related persons are reviewed against applicable sanctions lists and PEP criteria.
Risk Assessment
The risk level is determined by taking into account the characteristics of the customer, country, activity and transactions.
Monitoring and Records
The business relationship is monitored on a risk basis; review and control records are kept in accordance with the legislation.
Continuous AML Compliance Management.
AML compliance is not limited to initial registration and policy preparation. Controls need to be carried out and updated regularly in line with customer relationships, changes in activity and regulatory requirements.
- 01Initial Assessment and Compliance Structure
The business's AML obligations and risks are identified; the necessary policy, procedure and control mechanisms are established.
- 02Customer Due Diligence and Risk Controls
Identity verification, beneficial owner identification, customer risk classification and sanctions screening processes are carried out.
- 03Ongoing Monitoring and Reporting
Customer relationships and transactions are monitored on a risk basis; the necessary review, escalation and reporting processes are operated.
- 04Periodic Review and Update
Risk assessments, internal policies, records and control processes are reviewed in line with changes in activity and legislation.
Consequences of Non-Compliance with AML Obligations.
A breach of AML and regulatory compliance obligations may have financial, administrative and operational consequences, depending on the nature and scope of the breach and the assessment of the relevant authority.
- Administrative Fines
A breach of AML legislation and related regulatory obligations may lead to administrative fines, depending on the type and seriousness of the breach.
- Restrictions on Activity
Serious or repeated compliance breaches may lead to administrative measures, such as the restriction or temporary suspension of activities by the competent regulatory authorities.
- Licence and Regulatory Sanctions
Within the framework of the relevant legislation and the powers of the authority, some breaches may result in additional sanctions affecting licences or activity permits.
- Impact on Banking Relationships
Missing or outdated compliance documents may lead banks to request additional review, restrict transactions or reassess the customer relationship.
Integrated Corporate Services.
AML and regulatory compliance are closely linked to your business's financial and corporate governance processes. At Ortac Global, we provide complementary professional services in accounting, banking, corporate advisory and company formation.
Frequently Asked Questions.
No. goAML registration is mandatory for defined activities such as real estate brokerage, precious metals and stones trading, accounting, audit and corporate service provision. The beneficial owner register, however, applies to every company.
Yes. In a single-shareholder company, the beneficial owner is the company's shareholder, and the register entry is still created.
No notification is submitted for financial years ending after 31 December 2022. Obligations relating to the 2019-2022 periods, however, continue.
Yes. A company not carrying on activity does not by itself remove licence renewal, tax, accounting and other legal obligations. If the company will not be used, it needs to be formally closed.
Banks are also subject to anti-money laundering legislation. They are required to verify the ownership structure, actual activity and source of funds with documents.
No. The decision to open an account rests with the bank concerned; the application documents are prepared by us in the form the bank requires.
Once we are notified of the change, the beneficial owner and shareholder records are updated and the licensing authority is notified.