AML Internal Controls and Compliance Program Setup

The Importance of AML Compliance in the UAE

The UAE has made great progress in strengthening its anti-money laundering regime. Law firms and many professional service providers are also considered DNFBPs and must meet strict compliance obligations under the new legal regime.

The consequence of a failure to adopt effective internal controls on money-laundering and terrorist financing and on financial crime can involve an administrative fine up to AED 100 million against legal persons, suspension of licence, personal criminal liability for partners and compliance officers, and significant reputational harm.

A strong AML compliance program demonstrates your readiness to comply with the regulatory expectations, meets the due-diligence requests from banks and other partners and facilitates your business expansion in Dubai and the UAE.

Key UAE AML Laws and Requirements

• Federal Decree-Law No. 10 of 2025 – the main law regulating Money Laundering, Terrorist Financing and Proliferation Financing.
• Cabinet Resolution No. 134 of 2025 – the practical regulations issued by the government to be followed by financial institutions, DNFBPs and Virtual Asset Service Providers (VASPs).
• Ministry of Justice (MoJ) supervision of mainland law firms and legal practitioners (DFSA for DIFC; FSRA for ADGM).
• Mandatory goAML registration with the UAE Financial Intelligence Unit (FIU).
• Customer due diligence and ongoing monitoring on a risk-based basis and Suspicious Transaction Reporting (STR).

Your policies, procedures and controls should be documented and in line with your risk profile.

Core Pillars of an Effective AML Compliance Program

Enterprise-Wide Risk Assessment (EWRA)

Assess Money Laundering (ML), Terrorist Financing (TF), Proliferation Financing (PF) risks across clients, services, geographies, delivery channels, and transactions. Senior Management must approve and review it annually.

MLRO / Compliance Officer Appointment

Appoint Money Laundering Reporting Officer (MLRO) / Compliance Officer (CO) with UAE residency and independence. Generally Mainland firms need Ministry of Justice (MoJ) approval to complete goAML registration.

Risk Based CDD, SDD, EDD

Perform correct Know Your Customer (KYC) / CDD in order to identify customers and Ultimate Beneficial Owners (UBOs). Simplified Due Diligence (SDD) for low risk clients. Enhanced Due Diligence (EDD) for high risk clients, Politically Exposed Persons (PEPs) and complex structure.

Documented AML Policies & Internal Controls

Maintain clear documented Anti Money Laundering (AML) policies which cover client onboarding, risk scoring, ongoing monitoring, five (5) year record keeping, sanctions screening against the UAE Local Terrorist List and United Nations (UN) Consolidated List and confidential internal reporting.

goAML Registration & STR Filing

Register on the FIU’s goAML system. Make sure staff escalate red flags to the MLRO confidentially. File Suspicious Transaction Reports (STRs) without tipping off the client.

Staff Training & Independent Audit

To organise regular AML training and plan periodic independent AML audits to assess effectiveness and enable readiness to be inspected by supervisors.

Our AML Internal Controls and Compliance Programme Services

At RH & HALE, we help companies to establish an AML compliance framework that matches their size and regulatory obligations:

• Complete AML gap analysis against Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025
• Design or update of enterprise-wide risk assessment
• Drafting of tailored AML policies, procedures and internal controls
• MLRO appointment support and guidance on MoJ / goAML submission
• Complete goAML registration assistance
• Practical KYC / CDD / EDD framework and template design
• Sanctions screening and ongoing monitoring
• Key AML training sessions tailored to your role
• Independent AML audit, remediation plan and inspection readiness support
• Ongoing advisory on regulatory updates and UBO transparency requirements.

We avoid complex solutions that do not make sense for your firm’s size and risk level.

Who Needs AML Internal Controls and Compliance Program Setup?

We help the following clients:

• Law firms and legal consultancies operating in Dubai and mainland UAE
• Real estate agencies and property brokers
• Corporate and trust service providers
• Metal and stone dealers
• Audit and accounting firms
• Family offices and other DNFBPs facing direct scrutiny from banks or regulators.

Whether you want to establish a new programme or update existing controls in accordance with the latest AML laws and rules, we provide clear and actionable support.

Why Choose RH and Hale for AML Compliance in Dubai?

• RH and Hale is a well-established law firm based in Dubai with extensive experience in UAE regulatory and commercial issues.
• We combine detailed knowledge of the latest AML legislation and MoJ supervisory practice with sound legal advice that is realistic and practical for professional service firms.
• We focus on real compliance rather than common templates.
• We ensure that you are able to conduct your business with confidence and that all legal obligations are met.

Start Building Your AML Compliance Program

Avoid costly penalties, protect your firm and meet UAE AML compliance obligations with a programme designed specifically for your business. Contact RH and Hale Law firm for a confidential discussion or gap analysis.

We can assist you with developing effective AML internal controls and establishing a complete compliance program setup for your firm in Dubai and across the UAE.