UAE Strengthens Corporate Governance and AML Checks: What Businesses Need to Know
UAE Governance and AML Update · July 2026
The UAE Economic Integration Committee has discussed plans to strengthen corporate governance, anti-money laundering controls, inspections and the use of regulatory data. No new filing deadline was announced.
UAE companies should still check their ownership records, management approvals, customer files, goAML access and inspection documents.
Did the UAE introduce new corporate governance or AML rules in July 2026?
The Economic Integration Committee discussed plans to strengthen corporate governance, AML/CFT laws, inspections and the use of company data. The announcement did not introduce a new filing deadline. Existing rules already require UAE companies to keep accurate corporate and ownership records. DNFBPs must also complete goAML registration, customer due diligence, risk assessment, suspicious transaction reporting and AML record keeping.
What Did the UAE Economic Integration Committee Announce?
The Economic Integration Committee reviewed work covering corporate governance, anti-money laundering, counter-terrorism financing, market inspections, intellectual property, essential commodity monitoring and finance leasing.
For UAE businesses, the discussion points to closer checks of company records, internal approvals, ownership data and AML files. The meeting also referred to an AI-powered regulatory system and the National Programme for Developing Statistics System.
| Subject Discussed | What Businesses Should Check |
|---|---|
| Corporate governance | Ownership records, management authority, approval procedures, company registers and accountability. |
| AML/CFT legislation | Existing duties under the 2025 AML law, its executive regulations and the 2026 DNFBP guidelines. |
| Inspections | Current compliance files and clear proof that the written procedures are followed. |
| Use of regulatory data | Matching information across trade licences, UBO registers, tax files, bank records, accounts and customer documents. |
| Finance lease regulation | A separate policy subject covering finance leasing by legal persons outside Central Bank supervision. |
Existing UAE Company and AML Requirements
The announcement does not replace the company and AML requirements already in force. The exact duties depend on the business activity, legal form, licensing authority and financial or non-financial regulator.
| Law or Guidance | What It Covers |
|---|---|
| Federal Decree-Law No. 10 of 2025 | Money laundering, terrorism financing and proliferation financing. |
| Cabinet Resolution No. 134 of 2025 | Executive regulations supporting the 2025 AML law. |
| MoET DNFBP Guidelines, March 2026 | Risk assessments, customer checks, monitoring, reporting, AML records and staff training. |
| Cabinet Decision No. 109 of 2023 | Real beneficiary procedures and company ownership information. |
| Federal Decree-Law No. 32 of 2021 | Company formation, management, shareholder rights, records and corporate duties. |
| Capital Market Authority Governance Guide | Governance rules for public joint-stock companies and capital-market activities. |
A private LLC, real estate broker, listed company, bank and virtual-asset business do not follow the same compliance manual. Each business must check the requirements of its licensing and supervisory authorities.
Which UAE Businesses Are Most Affected?
| Business Type | Records and Procedures to Check |
|---|---|
| Private LLC or professional company | Ownership records, manager powers, company resolutions, UBO information, accounts and licence details. |
| Real estate broker or agent | Customer identification, beneficial-owner checks, source of funds, transaction records and goAML reporting. |
| Independent accountant or auditor | Client risk ratings, CDD files, higher-risk engagements, screening results and suspicious activity procedures. |
| Dealer in precious metals or stones | Cash transactions, high-value sales, sanctions checks, source-of-funds evidence and trade records. |
| Trust or company service provider | Company formation customers, ownership structures, nominee arrangements, registered addresses and ongoing customer checks. |
| Public joint-stock company | Board structure, committees, disclosures, conflicts of interest and related-party transactions. |
| Free zone company | Federal law, free zone rules, company registrar requirements and sector-specific obligations. |
Which Businesses Are DNFBPs in the UAE?
The Ministry of Economy and Tourism supervises the following main Designated Non-Financial Businesses and Professions:
- Real estate brokers and agents involved in property purchase or sale transactions for customers.
- Independent accountants and auditors providing professional services to third parties.
- Dealers in precious metals and stones, including businesses handling gold and diamonds.
- Trust and company service providers forming or administering companies and providing registered addresses.
Lawyers, financial institutions, virtual-asset service providers and financial free zone businesses operate under other supervisory authorities.
Corporate Governance Checks for UAE Companies
Corporate governance also applies to private UAE companies. Every business needs clear records showing who owns the business, who controls it and who has authority to make financial or legal decisions.
| Governance Area | What the Company Should Keep |
|---|---|
| Ownership and UBO information | An updated shareholder register, UBO register, ownership chart and nominee information. |
| Manager and board authority | Written confirmation of who can sign contracts, approve payments, hire staff, borrow money and deal with banks. |
| Approval limits | Clear approval levels for purchases, payments, loans and contracts. |
| Meetings and resolutions | Signed records of shareholder and board decisions. |
| Conflicts of interest | Declarations showing personal interests held by managers, directors or shareholders. |
| Financial records | Accurate accounts, reconciliations, invoices, supporting documents and management reports. |
| Consistent company information | The same legal name, ownership, activity and address across licences, banks, tax files and contracts. |
AML Requirements for UAE DNFBPs
1. Risk assessment and AML policies
Complete a Business Risk Assessment covering customers, countries, services, products, ownership structures, transaction values and payment methods. AML policies should explain customer acceptance, CDD, EDD, screening, transaction checks, reporting and record keeping.
2. Compliance Officer or MLRO
Appoint a qualified Compliance Officer or Money Laundering Reporting Officer with access to customer files, transaction information, senior management and goAML.
3. Customer and beneficial-owner checks
Identify the customer, authorised representatives and final beneficial owners. Complete extra checks for politically exposed persons, complex ownership structures, high-risk countries and unusual transactions.
4. Screening and transaction monitoring
Check customers and connected parties against sanctions and PEP lists. Keep dated screening results and compare transactions with the customer’s stated business and expected activity.
5. goAML and suspicious transaction reporting
Keep the entity and MLRO registration active on goAML. Staff should know how to report concerns internally so the MLRO can decide whether to submit an STR, SAR or another required report.
6. Records, training and testing
Keep AML records for at least five years, train staff whose work involves customers or transactions and test whether the procedures are followed.
What a Complete Customer Due Diligence File Should Contain
Collecting an Emirates ID does not complete customer due diligence. The file should show who the customer is, who controls the customer, why the transaction is taking place and how the customer obtained the funds.
| CDD Check | Documents and Records |
|---|---|
| Customer identity | Passport, Emirates ID, trade licence and incorporation documents. |
| Authorised representative | Board resolution, power of attorney or authorised signatory list. |
| Beneficial owner | Ownership chart, shareholder records and identity documents for the final natural person who owns or controls the business. |
| Purpose of the relationship | Engagement letter, property agreement, sale contract or written customer explanation. |
| Source of funds | Bank statements, salary records, sale agreements, business income or investment documents. |
| Customer risk rating | A recorded low, medium or high rating supported by the business risk model. |
| Screening results | Dated sanctions, PEP and adverse-information checks with staff review notes. |
UBO and Company Records to Keep Updated
A UAE company should identify the natural person who finally owns or controls the business. Where the ownership structure includes other companies, trusts or nominees, the file should document every level between the licensed business and its final owner.
- Real beneficiary or UBO register
- Shareholder or partner register
- Manager, director and authorised signatory details
- Nominee board member information
- Ownership chart for layered or foreign structures
- Identity and address documents for shareholders and UBOs
- Shareholder resolutions and share-transfer documents
- Proof that ownership changes were reported to the licensing authority
The information should match the trade licence, memorandum, bank KYC records, Corporate Tax registration and documents given to auditors.
Documents UAE Inspectors Can Request
| Inspection Subject | Documents to Keep Ready |
|---|---|
| Corporate governance | Organisation chart, authority limits, resolutions, meeting minutes and conflict declarations. |
| AML responsibility | MLRO appointment, senior management approval and AML reports submitted to management. |
| Business risk | Current Business Risk Assessment with scoring and management approval. |
| Customer files | CDD and EDD files with customer risk ratings, UBO documents and review dates. |
| Screening | Sanctions, PEP and adverse-information checks with dates and staff notes. |
| goAML | Entity registration, active MLRO access and internal reporting instructions. |
| Staff training | Training material, attendance records, test results and follow-up work. |
| AML testing | Internal audit or independent assessment results and records of completed corrections. |
Six Checks UAE Businesses Can Complete Now
- Confirm the requirements: Check the company’s legal form, licence activities, regulator and DNFBP status.
- Compare company records: Check that the licence, memorandum, UBO register, bank records and Corporate Tax information match.
- Test customer files: Select low, medium and high-risk customers and check identity, ownership, screening and source-of-funds documents.
- Check goAML access: Confirm that the entity registration and MLRO account are active and contain current information.
- Correct missing records: Update expired identification, ownership charts, customer risk ratings, training records and company resolutions.
- Record management approval: Give management a list of required corrections, name the person responsible and record the completion date.
Credora Corporate Governance and AML Services
Credora helps UAE companies check their governance, AML and company records before an internal audit, regulatory inspection or management review.
- Corporate governance review: ownership, management authority, resolutions, conflicts of interest and approval limits.
- Business Risk Assessment: assessment of customer, country, service, ownership and transaction risks.
- AML policy review: CDD, EDD, sanctions screening, transaction checks, reporting, records and staff duties.
- KYC file testing: sample checks of customer identity, UBO information, source of funds, risk ratings and screening results.
- UBO record review: ownership charts, registers, identity documents and checks against other company records.
- AML inspection file review: document list, staff briefing, management report and tracking of required corrections.
Credora provides governance, risk, internal control and documentation services. Legal advice, official filings and suspicious transaction reporting decisions remain the responsibility of the business, its appointed Compliance Officer or MLRO, its legal adviser and the relevant authority.
UAE Corporate Governance and AML FAQs
Disclaimer: This page provides general business and compliance information. It does not provide a legal opinion, guarantee regulatory compliance or replace instructions from the authority supervising the business.
