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Designated Non-Financial Businesses and Professions

As part of the UAE government’s efforts to prevent money-laundering, a series of guidelines for designated non-financial businesses and professions (“DNFBPs”) have been recently issued.

Such DNFBPs provide coverage amidst various high-risk industries, including:

  • Real Estate - Transactions involving the sale, purchase, leasing (or financing) of real estate have posed a great risk towards money laundering practices and, subsequently, facilitating further criminal operations.
  • Precious Metals and Stones – Cabinet Decision No. (10) of 2019 identified this category when dealers engaged in carrying out monetary transactions. Therefore, subjecting them to specific anti-money laundering and counter terrorism financing obligations under UAE legislation.
  • Accounting and Auditing Services – the UAE government, through its legislative framework, has implemented regulations on commercial companies and financial institutions to regulate the auditing profession. Specific obligations have been imposed on auditors with regard to the direct nature and content of their duties.
  • Company Service Providers – parties engaged as services providers should determine the appropriate policies, procedures and controls related to the adequate retention, organization and maintenance of records.
  • Legal Consultancy Firms (Except for Lawyers, and Notary Publics) – Pursuant with the UAE government's compliance regulations, the Ministry of Economy has introduced legal consultancy firms (except lawyers and Notary Publics) to the Designated Non-Financial Businesses and Professions list.

In light of the above, alongside supplemental guidance, the Ministry of Economy has issued circulars providing in-depth details of anti-money laundering practices in connection with the DNFBPs.

For more details about the circulars, please refer to the below links.

Circular No. 1/2021 - Real Estate Brokers and Agents
Circular No. 1/2021 - Real Estate Brokers and Agents
04/02/2021
 Circular No. 2/2021 - Dealers in of Precious Metals and Stones
Circular No. 2/2021 - Dealers in of Precious Metals and Stones
04/02/2021
 Circular No. 3/2021 - Account Auditors
Circular No. 3/2021 - Account Auditors
04/02/2021
 Circular No. 4/2021 - Company Services Providers
Circular No. 4/2021 - Company Services Providers
04/02/2021
 Circular No. 7/2021 - Legal Consultancy Firms
Circular No. 7/2021 - Legal Consultancy Firms
04/02/2021

The UAE has demonstrated a strong commitment to executing UN Security Council Resolutions (UNSCRs) and complying with UN sanctions regimes. As a result, through Cabinet Resolution No. 74 of 2020, the UAE is enforcing the UNSCRs on the suppression and combating terrorism, countering terrorist financing, and countering the financing of the proliferation of weapons of mass destruction, specifically targeted financial sanctions (TFS) regimes, as defined by the UN.

 Cabinet Decision No. 74 of 2020
Cabinet Decision No. 74 of 2020

Consistent with the UAE government’s ongoing efforts to minimize risk exposure, the Ministry of Economy has issued a list of high-risk jurisdictions and jurisdictions subject to increased monitoring.

Designated non-financial business and professions are required to, on a regular basis, review the lists and implement necessary actions. For further details regarding the Ministry of Economy’s circulars, please refer to the circular below.

Circular No. 6 of 2021 Concerning Updates on High-Risk Jurisdictions
Circular No. 6 of 2021 Concerning Updates on High-Risk Jurisdictions
30/03/2021
Circular No-MOEC-AML-001-2023 Concerning Update on the List of High Risk Jurisdictions
Circular No-MOEC-AML-001-2023 Concerning Update on the List of High Risk Jurisdictions

A cabinet decision number (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 has been issued, which specifies DNFBP obligations, some of which were later amended via The Cabinet Resolution No. (24) of 2022 Amending some provisions of Cabinet Resolution No. (10) of 2019 On the Executive Regulations of Federal decree-Law No. (20) of 2018 on Combating Money Laundering and the Financing of Terrorism and illegal Organisations.

The Cabinet Decision No. (10) of 2019 Concerning the Implementing Regulation of Decree Law No (20) of 2018 on Anti-Money Laundering and Combatting the Financing of Terrorism and Illegal Organisations.
The Cabinet Decision No. (10) of 2019 Concerning the Implementing Regulation of Decree Law No (20) of 2018 on Anti-Money Laundering and Combatting the Financing of Terrorism and Illegal Organisations.
The Cabinet Resolution No. (24) of 2022 Amending Some Provisions of Cabinet Resolution No. (10) of 2019 on the Executive Regulations of Federal Decree-law No. (20) of 2018 on Combating Money Laundering and the Financing of Terrorism and Illegal Organizations.
The Cabinet Resolution No. (24) of 2022 Amending Some Provisions of Cabinet Resolution No. (10) of 2019 on the Executive Regulations of Federal Decree-law No. (20) of 2018 on Combating Money Laundering and the Financing of Terrorism and Illegal Organizations.

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