The AML law in the UAE applies to financial institutions, insurance companies, banks and certain non-financial businesses and professions that falls into the classification of Designated Non-Financial Businesses andprofessions (DNFBP), as listed below, must comply with cabinet Decision No. (10) of 2019 Concerning the implementing regulation of decree- law no.(20) of 2018 on Anti Money Laundering and combating the financing of terrorism and illegal organizations.

- Real estate agents;

- Dealers in preciousmetals;

- Dealers in precious stones;

- Lawyers, notaries, other independent legal professionals and accountants. This refers to sole practitioners, partners or employed professionals within professional firms. Itis not meant to refer to internal professionals that are employees of othertypes of businesses, nor to professionals working for government agencies, who may already be subject to AML/CFT measures

- Trust and Company Service Providers. This refers to all persons or businesses that are not covered elsewhere under these Recommendations, and which as a business, provideany of the following services to third parties:

a. acting as a formationagent of legal persons

b. acting as (or arrangingfor another personto act as) a directoror secretary of a company,a partner of a partnership, or a similar position in relation to otherlegal persons

c. providing a registered office,business address or accommodation, correspondence or administrative address for a company, a partnership or anyother legal person or

arrangement;

d. acting as (or arranging for another personto act as) a trusteeof an express trust or performing the equivalent function foranother form of legal arrangement

e. acting as (or arranging for another personto act as) a nomineeshareholder for another person

All appointed shareholders, must adhere to the following guidelines:

1. Develop an adequate governance framework forAML/CFT, including the appointment of an AML/CFT Compliance Officer at a management level, who will be responsible for day-to-day oversightfor AML/CFT matters and ensuring adequate staff screening and training.

2. Establish, implement, monitor,and maintain an effective compliance program in line with DFNBP’S guidelines.

3. Register in the AML platform Suspicious Transaction Reporting System.

4. Subscribe to UAE Sanction lists to receive frequent updates.

5.  Maintain adequate risk-based due diligence and ongoing monitoring procedures.

6.  Maintaining all recordsrelated to the above, obtained through due diligence measures, accountfiles, and business correspondence, including the results of any risk analysis undertaken, for at least fiveyears after the business relationship is ended, or after the date of anoccasional transaction.

7.  Ensure an independent audit system that will benchmarkthe effectiveness of these Guidelines on a risk-sensitive basis; thisreview shall have a defined minimum frequency.

Failure to register your business on AML platform may result penalties. Contact us for more information about AML regulations in the UAE.