Risk Advisory

Anti Money Launderings

Detect. Prevent. Comply—your First Line of Defense Against Money Laundering.

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ASC Group provides end-to-end anti money laundering (AML) compliance services to help businesses meet mandatory obligations under UAE anti money laundering law. Our AML solutions are tailored to financial institutions, DNFBPs, and corporate entities seeking to establish or enhance strong internal controls. We help you mitigate financial crime risks, avoid regulatory penalties, and maintain market integrity in a highly monitored regulatory ecosystem.

Key Benefits

Regulatory Compliance

Adherence to Federal Law No. 10 of 2025 (effective 14 October 2025), Cabinet Decision 10/2019, and FATF standards for combating money laundering, terrorist financing, and proliferation financing.

Risk Mitigation

Risk-based AML frameworks, monitoring systems, and suspicious transaction reporting

Reputation Protection

Risk-based AML frameworks, monitoring systems, and suspicious transaction reporting

Operational Efficiency

Risk-based AML frameworks, monitoring systems, and suspicious transaction reporting

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Legal & Regulatory Landscape

Primary Laws & Regulations:

Federal Decree Law No. 20 of 2018

Core anti money laundering act for all UAE entities

Cabinet Decision No. 10 of 2019

Executive rules for AML compliance in UAE

CBUAE Circular No. 24/2019

AML/CFT compliance for financial institutions

MOF Guidelines

AML duties for DNFBPs including real estate, auditors, dealers, and CSPs

GoAML Registration Requirement

Mandatory for all reporting entities to file anti money laundering reporting via FIU platform

PROCESS & TIMELINE

Our Streamlined AML Process

Phase 1

Initial Consultation

Understand your business model, industry, and regulatory exposure

Timeline: 2–3 working days

Phase 2

Risk Profiling & Documentation Review

Identify gaps in KYC/CDD/STR reporting frameworks

Tentative Duration: 1–2 weeks

Phase 3

Policy Design & GoAML Enablement

Draft AML program documents, assist with GoAML registration

Tentative Duration: 2–4 weeks

Phase 4

Training & Implementation

Conduct training and support operational implementation

Timeline: Ongoing

Compliance Requirements

Regulation / Guideline

Federal Decree Law No. 20 of 2018 (Core AML Legislation)

CBUAE Circular 24/2019 (Central Bank AML Guidelines)

MOF AML Guidelines / Cabinet Decision No. 10/2019 (For DNFBPs)

GoAML Reporting – FIU Platform

Scope & Applicability

Applies to all natural and legal persons in the UAE (including FIs and DNFBPs).

Lawyers & Legal Consultants (DNFBP category - client fund handling)

VASPs in the UAE must register on GoAML, use blockchain analytics, comply with the Travel Rule, file daily FIU reports, and secure a VARA or SCA license.

Applies to all FIs & DNFBPs for reporting suspicious transactions to FIU via GoAML

Penalties for Non-Compliance

Regulation / Guideline Penalties for Non-Compliance

Federal Law No. 10 of 2025 (Core AML Legislation - Effective 14 October 2025)

 Companies: AED 10,000–5 million per violation | Individuals: 1–14 years imprisonment | Manager Personal Liability: Individual criminal prosecution + fines | Average enforcement fine: AED 15 million (2024-2025 data)

CBUAE Circular 24/2019 (Central Bank AML Guidelines)

 Fines from AED 50,000 to AED 10 million – Restrictions on operations – Public reprimand – Regulatory sanctions on management

MOF AML Guidelines / Cabinet Decision No. 10/2019 (For DNFBPs)

 Fines from AED 50,000 to AED 1 million – Up to AED 5 million for repeated offenses – Risk of criminal referral and license

GoAML Reporting – FIU Platform (Mandatory for all regulated entities)

 Fines up to AED 500,000 for failures – Regulatory scrutiny – Portal access denial – Increased audit risk

Manager Personal Liability (Individual criminal exposure)

 Criminal prosecution: Up to 14 years imprisonment

Proliferation Financing Coverage (WMD, arms trafficking, dual-use goods)

 Criminal penalties: Up to 10 years imprisonment

Key AML Risk Categories

Risk Type Examples

Customer Risk

 PEPs, shell companies, anonymous account holders

Geographic Risk

 Transactions involving high-risk jurisdictions (as per UAE FIU/FATF lists)

Product/Service Risk

 Cross-border remittances, crypto, private banking, complex structures

Channel Risk

 Non-face-to-face onboarding, third-party intermediaries

Transaction Risk

 High-volume cash deposits, unusual fund movements, structured transfers

VASP Risk (NEW)

 Wallet mixing services, unhosted wallets, P2P transfers, cross-chain bridges, darknet activity

Digital Systems Risk (NEW)

 Digital system misuse, encryption evasion, blockchain-based AML, virtual asset layering

AML Thresholds by Transaction Type (Indicative)

Currency Type

AED (Cash)

Wire Transfer (AED)

Foreign Currency (USD/GBP/INR)

Virtual Assets (Crypto)

Gold/Jewelry/High-Value Assets

Real Estate Transactions

Threshold for Monitoring

Cash deposits ≥ AED 55,000

Single transfer ≥ AED 100,000

Equivalent to AED 100,000

Any VASP transaction → KYC required + Blockchain analytics screening + Daily FIU reporting

Purchase ≥ AED 55,000

≥ AED 55,000 in cash or 3rd-party cheques

Mandatory Reporting Trigger

Suspicious Transaction Report (STR) or Cash Transaction Report (CTR)

Electronic Fund Transfer (EFT) Reporting under GoAML

FX conversion or offshore movement triggers enhanced due diligence

+ STR filing within 3-5 business days if suspicious

KYC + STR required under MOF DNFBP guidelines

Mandatory disclosure to FIU through GoAML portal

*Note: All thresholds are subject to change based on UAE Central Bank, FIU, and Ministry of Economy notifications. Always apply risk-based assessment beyond monetary limits.

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Our Comprehensive AML Solutions

We offer end-to-end AML advisory, implementation, and support services tailored to meet regulatory requirements and industry-specific risk profiles. Our team works closely with clients to build proactive compliance structures that withstand audits and inspections.

Service Offerings

Phase 1

AML Policy & Framework Development

Risk-based AML/CFT program design

Drafting AML policy, SOPs, and escalation protocols

Regulatory alignment (CBUAE, MOF, DFSA, etc.)

Phase 2

KYC & CDD Implementation

Customer onboarding procedures

Beneficial ownership identification

Risk profiling of clients and counterparties

Phase 3

GoAML Registration & STR Filing

Support with registration on UAE FIU GoAML platform

STR/SAR filing process design

Documentation and reporting formats

Phase 4

AML Training & Awareness

AML training workshops for employees and management

Role-specific training for compliance teams and MLROs

Sector-focused AML simulation cases

Arabic/English workshops for compliance officers

CBUAE-approved e-learning modules

Phase 5

Internal Audit & AML Health Check

Gap assessments against legal requirements

Risk control matrix development

Internal review reporting and audit preparedness

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Why Choose us

Your Trusted AML Compliance Partner in UAE

End-to-end advisory and anti money laundering services

End-to-end advisory and anti money laundering services

Experience with anti money laundering compliance officer responsibilities

Experience with anti money laundering compliance officer responsibilities

Deep knowledge of GoAML, FATF, and CBUAE AML systems

Deep knowledge of GoAML, FATF, and CBUAE AML systems

Guidance for anti money laundering registration, STR, and monitoring

Guidance for anti money laundering registration, STR, and monitoring

Support for ICA certificate in anti money laundering and e-learning

Support for ICA certificate in anti money laundering and e-learning

Customized, cost-effective AML packages for regulated entities

Customized, cost-effective AML packages for regulated entities

ASC Group is committed to building integrity-driven businesses. We ensure our clients remain compliant, resilient, and audit-ready — while minimizing operational disruption and reputational risk.

Tailored AML Compliance Solutions Across UAE Regulatory Frameworks with ASC Group: GoAML, CBUAE, MOF & DNFBP-Aligned Advisory for Financial & Non-Financial Entities

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Expert advisory services for UAE, corporate & compliance solutions. Professional excellence delivered globally.

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Related Services

Corporate Governance
Internal Control Over Financial Reporting (ICFR)
Standard Operating Procedure
Internal Audit
Physical Verification Services
Business Continuity Planning (BCP)
Enterprise Risk Management
Forensic Investigation
MIS Reporting
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Frequently Asked Questions

All financial institutions and DNFBPs (like real estate firms, accountants, and dealers in precious metals) are required to comply under UAE Federal Law No. 20 of 2018.

It is the online platform provided by the UAE Financial Intelligence Unit (FIU) for suspicious transaction reporting (STR/SAR). Registration is mandatory for regulated entities

Best practice recommends a yearly review, or earlier if there are significant regulatory or operational changes.

Yes. We provide on-site AML training programs customized to your industry and role level.

Annually, or after major business changes (new products, geographies).

Our Team is completely capable of providing e-learning covering all staff globally.

Federal Law No. 10 of 2025 (effective 14 October 2025) replaces the 2018 AML framework. It covers money laundering, terrorist financing, and proliferation financing. Personal liability for managers is now included. VASPs are explicitly regulated. No limitation periods apply to financial crimes.

Companies face fines up to AED 5 million per violation. Individuals face 1-14 years imprisonment. Managers have personal criminal liability. Average enforcement fine: AED 15 million. License suspension possible. Asset freezing up to 30 days by FIU.

GoAML is the FIU platform for reporting suspicious transactions. Registration is 2-stage: (1) SACM registration (5-10 days), then (2) GoAML portal registration (2-5 days). You receive a unique registration number required for all STR filings.

CDD is mandatory customer verification to prevent money laundering. Three tiers exist: Standard CDD (most customers), Simplified CDD (low-risk), Enhanced CDD (high-risk/PEPs). Documentation includes ID, address proof, source of funds, and beneficial ownership information.

Beneficial ownership identifies individuals controlling 25%+ of a company. Required steps: obtain ownership structure, identify all owners, collect IDs, verify source of funds, screen against PEP/sanctions lists. Update annually. Retain documentation 5+ years.

File STRs for suspicious activity (unusual patterns, high-risk indicators, PEP involvement, unclear source of funds). Timeline: Report to compliance officer within 24 hours; file to FIU within 3-5 business days. Identify suspicious activity within 72 hours.

EDD applies to high-risk customers: PEPs, high-risk jurisdictions, complex structures, cash-intensive businesses. Requirements: Senior management approval, deep investigation, source of wealth verification, ongoing monitoring, quarterly reviews. Proper EDD reduces regulatory audit risk.

Collect customer identification and screen against OFAC, EU, UN, FATF, and UAE FIU lists. Document results. If matched: report to compliance officer and file STR. Use automated screening tools with daily updates. Screen beneficial owners and directors too.

ESR requires businesses to conduct real operations in the UAE, not just serve as pass-through structures. Substance includes: real employees, physical offices, local expenditures, UAE decision-making, local bank accounts. Lack of substance triggers stricter AML requirements.

Required: AML policy, customer acceptance policy, CDD/KYC procedures, STR procedures, record retention policy, training program. Annual training for all employees. Role-specific training for compliance teams. Board oversight documented in minutes. Federal Law 10/2025 updates required.

VASPs (crypto providers) must register on GoAML, implement blockchain analytics, monitor transactions daily, comply with travel rule, maintain cold wallet controls, screen sanctions lists, file STRs for suspicious activity. Licensing required (VARA/SCA). Daily FIU reporting mandatory.

STR = Suspicious transactions (judgment-based, no fixed threshold, 3-5 day filing) CTR = Currency transactions AED 55,000+ (mechanical threshold, all entities report, timing varies) Both mandatory. STR non-compliance = AED 5M penalty. CTR non-compliance = AED 1M penalty.

Minimum 5 years from account closure or transaction completion. Best practice: 7-10 years (Federal Law 10/2025 has no limitation periods). Retain: CDD/KYC docs, STR files, monitoring reports, screening results, training records, board minutes, compliance policies.

Inspectors review AML policies, training records, customer files, transaction monitoring, STR records, GoAML registration, and governance. Common findings: incomplete CDD, weak monitoring, delayed STRs. Post-inspection: 30 days to remediate. Penalties: fines (AED 10K-5M), license suspension, criminal referral.

Annual compliance cost: AED 400,000–1,000,000 Non-compliance cost per incident: AED 3–12 million (fines, legal, remediation, reputational) Real data: Average AML fine = AED 15 million. ROI: Investing AED 500K to avoid AED 5M fine = 10:1 return.

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UAE

UAE

Office 04 - 1803, 18th floor, One by Omniyat Business bay, Dubai

Canada

Canada

302-18 Edgecliff Golfway, North York, Toronto, Ontario M3C 3A3

E.U.

E.U.

Via F.lli Gabba 3, 20121 – Milan, Italy

China

China

RM2106, Huishangsha Edifice, No.37, Baoshi West RD, Shiyan Town, Bao’an District, Shenzhen - 518108, China

India

India

C-100, Sector 2, Noida (UP), Delhi NCR, India 201301

Singapore

Singapore

One Raffles Place, Tower 1, 27-03 Singapore - 048616

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