Bribery

Last Updated: 04/20/2026

Protect your business with reliable and effective AML strategies with AML UAE.

Bribery as a Predicate Offence: UAE AML Risks, Laws and DNFBP Obligations

Federal Decree-Law No. 10 of 2025 | Federal Decree-Law No. 31 of 2021 | Cabinet Resolution No. 134 of 2025 | FATF Recommendation 3 | UNCAC (Federal Decree No. 8 of 2006)

KEY TAKEAWAYS

Bribery is a FATF-designated predicate offence under the category of “corruption and bribery”, meaning proceeds derived from it fall within the scope of money laundering prosecution under UAE Federal Decree-Law No. 10 of 2025.
Under Federal Decree-Law No. 31 of 2021 (Articles 275 to 287), bribery is criminalised across the public sector, foreign officials, employees of international organisations, and the private sector. Private sector bribery under Articles 278 and 279 carries imprisonment for up to five years.
DNFBPs must file a Suspicious Transaction Report (STR) via the goAML portal whenever bribery-related activity is suspected, with no minimum transaction threshold, subject to the confidentiality and no-disclosure rules under Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
The Ministry of Economy and Tourism (MoET) is the principal AML/CFT supervisor for DNFBPs at state level and in commercial free zones, while the Ministry of Justice (MoJ) supervises lawyers and notaries. The Central Bank of the UAE (CBUAE) supervises licensed financial institutions.
Foreign PEPs must be subject to Enhanced Due Diligence (EDD), source of funds and wealth measures, senior management approval, and enhanced ongoing monitoring.
Domestic PEPs and persons entrusted with a prominent function in an international organisation require these enhanced measures where a high-risk business relationship exists.

Introduction to Bribery as a Financial Crime Risk

Bribery is the offering, giving, receiving, or soliciting of anything of value to influence the actions of an official or decision-maker, whether in the public or private sector. It is one of the oldest and most corrosive financial crimes. Within the AML/CFT framework, bribery is important not only as a crime in its own right but because it generates illicit proceeds that must be laundered before they can be used. That laundering process is exactly what UAE AML/CFT legislation is designed to detect and disrupt.

Bribery sits within the broader category of corruption. Not all corruption involves bribery, but all bribery is a form of corruption. Kickbacks are a specific subset: a bribe paid upfront secures a favour before a decision, while a kickback is a payment made after the transaction and is typically structured as a return of a portion of a contract value to the person who arranged or approved the deal. Both generate criminal proceeds that trigger money laundering liability under UAE law.

For UAE Regulated Entities, bribery risk is especially relevant because of three structural features of the UAE economy: a high concentration of cross-border transactions, a large foreign official and PEP population among residents and clients, and significant activity in sectors that are natural vehicles for integrating bribery proceeds, such as real estate, precious metals, and corporate structuring services.

How Bribery Proceeds Are Laundered

Proceeds generated from bribery are typically laundered through the three-stage process recognised by FATF and adopted in the UAE AML doctrine. Understanding how bribe proceeds move through each stage helps DNFBPs identify and disrupt the money laundering cycle at its most exposed points.

Stage 1 | Placement

Bribe proceeds enter the financial system through cash deposits, structuring (smurfing) across multiple accounts, or the purchase of high-value goods such as luxury vehicles, watches, gold, and jewellery. These are all sectors encountered by UAE DNFBPs, especially dealers in precious metals and stones (DPMS) and real estate agents and brokers.

Stage 2 | Layering

Funds are moved through shell companies, nominee directors, offshore trusts, and back-to-back corporate structures to obscure the audit trail. Free zone entities and trust-and-company-service-provider (TCSP) arrangements are historically exploited at this stage, which is why TCSPs and corporate service providers face heightened bribery-proceeds exposure.

Stage 3 | Integration

Clean-looking funds re-enter the economy via real estate acquisitions, equity investments, art and luxury purchases, or invoiced professional services. All of these sectors sit within the DNFBP perimeter under Cabinet Resolution No. 134 of 2025 and therefore carry mandatory AML/CFT obligations

Because DNFBPs are frequently exposed to high-value assets, complex ownership structures, and transactions that raise questions about the legitimacy of underlying funds, they occupy a particularly sensitive position in the laundering cycle. Federal Decree-Law No. 10 of 2025 (Article 16 and related provisions) requires Regulated Entities (REs), including DNFBPs, to report any transaction suspected to be associated with a predicate crime through a Suspicious Transaction Report (STR) filed on the goAML portal, operated by the UAE Financial Intelligence Unit (FIU).

UAE Legal and Regulatory Framework Addressing Bribery

The UAE maintains a comprehensive legal architecture addressing bribery, corruption, and their intersection with money laundering. Understanding how these instruments interact is essential for any DNFBP conducting a risk assessment or designing compliance controls.

Federal Decree-Law No. 31 of 2021 | Crimes and Penalties Law

Federal Decree-Law No. 31 of 2021 (the Crimes and Penalties Law, commonly called the UAE Penal Code) is the primary instrument criminalising bribery in the UAE. It covers public sector bribery, foreign public official bribery, bribery of employees of international organisations, private sector bribery, and intermediary liability across Articles 275 to 287.

Articles 275 and 276 | Bribery of foreign public officials and employees of international organisations, including cases where the foreign official mistakenly assumed the act fell within their duties.
Articles 278 and 279 | Private sector bribery. Article 278 criminalises the demand or acceptance of an undue gift, benefit, or grant by a manager of a private company in return for an act or omission connected to their duties. Article 279 criminalises the offering or granting of a bribe to such a private sector manager. The penalty for both offences is imprisonment for up to five years.
Articles 280 and 281 | Domestic public official bribery, including facilitation payments, which are not permitted under UAE law and are prosecuted as bribery.
Articles 282 and 283 | Intermediary liability, applying to any person acting as a go-between in demanding, offering, receiving, or promising a bribe.
Articles 284 to 287 | Ancillary provisions including aggravating circumstances, confiscation of the bribe amount, and related penalties.

A note on terminology: “temporary imprisonment” under the UAE Penal Code is a custodial sentence of between three and fifteen years, as distinguished from life imprisonment or short-term detention. Where Articles 278 and 279 cap private sector bribery at five years, this is a specific deviation from the general temporary imprisonment range for bribery offences.

Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025

Federal Decree-Law No. 10 of 2025 (the AML/CFT/CPF Law) and Cabinet Resolution No. 134 of 2025 (its Executive Regulations) work together as the core operational framework for combating money laundering in the UAE. The 2025 Law replaced Federal Decree-Law No. 20 of 2018 and came into force on 14 October 2025. Cabinet Resolution No. 134 of 2025 replaces Cabinet Decision No. 10 of 2019.

A predicate offence is defined under Article 1 of the 2025 Law as any crime whose proceeds may be subject to a money laundering offence, whether committed inside or outside the UAE, provided the conduct is punishable in both jurisdictions. Bribery falls squarely within this definition. Any profit derived from bribery that is subsequently concealed, converted, transferred, acquired, possessed, or used triggers a separate money laundering offence, in addition to the underlying bribery charge.

The 2025 Law introduces several important changes that are directly relevant to bribery-related compliance:

Lowered evidentiary threshold (Article 2). A person commits money laundering if they know, or have sufficient or circumstantial evidence supporting knowledge, that funds derive from a predicate crime. Actual knowledge is no longer required; inference from objective circumstances is enough. This is critical for bribery cases where direct evidence is rare.
Autonomy of the ML offence. A conviction for the underlying bribery is no longer required to prosecute money laundering of bribery proceeds. The two offences stand independently and may be prosecuted cumulatively.
Confidentiality and no-disclosure (Article 24 and Article 29). Article 24 of the 2025 Law and Article 19 of Cabinet Resolution No. 134 of 2025 prohibit DNFBPs, their directors, officers, and employees from disclosing to a customer or any third party that an STR has been filed, or that related information has been shared with the FIU, or that an investigation is underway. Article 29 sets out the criminal penalties for breach, which apply to both intentional and grossly negligent disclosures. This applies directly to bribery STRs involving PEPs or intermediaries.
Higher penalties. Corporate fines of up to AED 100 million and individual custodial sentences of up to 10 years for principal ML offences, with removal of limitation periods for ML, TF, and PF offences.

FATF Recommendation 3 and the Predicate Offence Framework

FATF Recommendation 3 requires countries to criminalise money laundering on the basis of all serious offences, with a view to including the widest possible range of predicate offences. The FATF Glossary sets out a list of “designated categories of offences” that must be captured, and “corruption and bribery” is one of those categories. The UAE has adopted this framework through Federal Decree-Law No. 10 of 2025 and the UAE National AML/CFT/CPF Strategy, and is aligned with the national risk assessment (NRA) and the sectoral risk assessments (SRAs) issued by competent authorities.

At the international level, the UAE is a signatory to the United Nations Convention Against Corruption (UNCAC), ratified domestically through Federal Decree No. 8 of 2006. UNCAC provides the legal foundation for cross-border anti-bribery cooperation, asset recovery, and mutual legal assistance. The UAE is also a signatory to the Arab Anti-Corruption Convention.

Supervisory Authority Framework for DNFBPs

Supervisory responsibility for DNFBPs in the UAE is divided across multiple authorities according to sector:

Ministry of Economy and Tourism (MoET). The primary AML/CFT supervisory authority for DNFBPs in the UAE mainland and commercial free zones. MoET supervises real estate agents and brokers, dealers in precious metals and stones (DPMS), independent accountants and auditors, and corporate service providers. MoET issues AML/CFT guidance, conducts onsite and offsite inspections, and imposes administrative penalties under Cabinet Resolution No. 16 of 2021, which sets out the unified list of violations and fines ranging from AED 50,000 to AED 1,000,000 per violation.
Ministry of Justice (MoJ). Supervises lawyers and notaries, who are DNFBP sub-categories carved out of MoET’s jurisdiction. Legal professionals carry heightened bribery exposure because of their involvement in corporate structuring, trust arrangements, and real estate conveyancing.
Central Bank of the UAE (CBUAE). Supervises licensed financial institutions, including banks, exchange houses, insurance intermediaries, and payment service providers. The CBUAE requires licensed FIs to embed anti-bribery considerations within their Enterprise-Wide Risk Assessment (EWRA) and to apply EDD to PEPs and high-risk relationships.
DFSA (DIFC) and FSRA (ADGM). Supervise entities operating in the financial free zones under their own AML rules, read alongside federal AML legislation.
UAE Financial Intelligence Unit (FIU). Operates the goAML portal and receives all STRs and SARs. Under the 2025 Law, the FIU has expanded powers to freeze suspected funds for up to 30 days (extendable by the Public Prosecutor) and enhanced coordination authority with domestic and foreign counterparts.

Common Bribery Typologies Relevant to UAE DNFBPs

Criminals exploit a range of methodologies when committing bribery and laundering the resulting proceeds. The following typologies are particularly relevant to UAE-based Regulated Entities and their client profiles, and should be explicitly addressed in the EWRA and transaction monitoring calibration.

Agent and Intermediary Abuse

Criminals frequently use intermediaries, consultants, agents, and sales representatives to conceal bribes and create plausible commercial cover for illicit payments. Payments routed through third parties without a clear commercial justification are the primary indicator of this typology. Common red flags include agents based in jurisdictions unrelated to the commercial activity, commission rates materially above market norms, and invoices for services that cannot be independently verified.

Procurement Fraud and Kickback Schemes

Kickback schemes enable suppliers, procurement staff, or intermediaries to secure tenders and contracts in exchange for a share of the contract value. Related conduct includes inflated invoicing, bid rigging, sham subcontracts, fake commissions, and the misclassification of bribe payments as legitimate marketing, consultancy, or entertainment expenses. DNFBPs operating in procurement-heavy sectors, or providing services to clients in such sectors, should monitor for these patterns.

Real Estate Sector Exposure

Transactions in the UAE real estate sector, including the sale and purchase of off-plan and completed properties, are particularly susceptible to misuse. The high value, relative opacity of beneficial ownership in layered structures, prevalence of cash components, and common use of intermediaries make real estate a preferred vehicle for integrating bribery proceeds. UAE-licensed real estate agents and brokers must remain alert to this exposure, and MoET has issued sector-specific red flag guidance for real estate professionals.

PEP Exploitation and Cross-Border Risks

Bribery disproportionately targets individuals in positions of authority, including foreign officials and those classified as Politically Exposed Persons (PEPs) under the FATF definition. PEPs may be foreign, domestic, or persons entrusted with a prominent function in an international organisation, and their family members and close associates are treated as PEPs for EDD purposes.

Under Cabinet Resolution No. 134 of 2025, foreign PEPs are subject to EDD, source of funds and wealth measures, senior management approval, and enhanced ongoing monitoring as standing requirements.

Domestic PEPs and persons entrusted with a prominent function in an international organisation require these enhanced measures where a high-risk business relationship exists.

Cross-border transactions heighten the risk of ML, illicit fund movement, tax evasion, and terrorism financing. PEP-related bribery risk also intersects with Targeted Financial Sanctions (TFS) obligations under Cabinet Decision No. 74 of 2020.

Red Flags for Identifying Bribery-Related Suspicious Activity

The following indicators require prompt escalation to the compliance function and, where the suspicion threshold is met, submission of an STR via goAML. Priority is indicated on a two-tier basis: High priority indicators typically warrant immediate MLRO escalation, while Medium priority indicators warrant enhanced monitoring and may rise to High when compounded by other factors.

Red Flag Indicator	Category	Priority
Payments to or from agents or consultants with no clear commercial rationale, or commission rates materially above market norms	Transaction / Relationship	High
Cash-intensive transactions without a verifiable source of funds, especially in real estate or DPMS contexts	Transaction	High
Inflated invoices, sham contracts, or unexplained commission payments structured as marketing or consultancy fees	Transaction	High
Use of complex corporate structures, nominee arrangements, or back-to-back entities obscuring the Ultimate Beneficial Owner (UBO)	Structural	High
Foreign PEP involvement in a business relationship without clear commercial justification	Customer / Relationship	High
Transactions routed through high-risk jurisdictions, FATF-listed jurisdictions, or offshore secrecy jurisdictions	Jurisdictional	High
Domestic PEP or PEP family member onboarding without jurisdictional or transactional risk compounding factors	Customer / Relationship	Medium
Frequent round-sum transactions or structured cash deposits below reporting thresholds	Transaction	Medium
Rapid movement of funds across multiple accounts or jurisdictions with no discernible business logic	Transaction	Medium
Customer reluctance to provide source of wealth or UBO information in line with MoET CDD expectations	Behavioural	Medium

DNFBPs should integrate name-screening, transaction-monitoring, and adverse-media-screening tooling into their compliance systems to detect these indicators at scale, rather than relying on manual detection alone.

Best Practices for Preventing and Detecting Bribery

Regulated Entities must adopt a proactive approach to both preventing and detecting bribery. The following practices represent the standard expected by MoET, CBUAE, and other supervisors, and align with Cabinet Resolution No. 134 of 2025 and the UAE National AML/CFT/CPF Strategy.

Incorporate bribery and corruption as standalone risk categories within the Enterprise-Wide Risk Assessment (EWRA), rather than treating them as generic predicate offences. The NRA and SRAs should be explicitly referenced.
Conduct comprehensive due diligence on all customers, including third parties, intermediaries, agents, and business partners. This includes Know Your Business (KYB) checks, UBO identification and verification, and source of wealth and source of funds verification for high-risk relationships.
Apply Enhanced Due Diligence (EDD) to foreign PEPs as a standing requirement, and to domestic PEPs and persons entrusted with a prominent function in an international organisation where a high-risk business relationship exists. EDD extends to their family members and close associates, and to customers with connections to high-risk or offshore jurisdictions.
Calibrate transaction monitoring systems to detect bribery-related patterns such as inflated invoices, unexplained agent commissions, structured cash transactions, and round-sum transfers to jurisdictions inconsistent with the customer profile.
Monitor procurement and contract management processes for both the entity itself and its clients, since these stages present the greatest kickback exposure.
Establish a whistle-blower policy and confidential internal reporting channels that protect staff who report suspected bribery, consistent with UAE regulatory expectations and the confidentiality and no-disclosure rules in Article 24 of Federal Decree-Law No. 10 of 2025 and Article 19 of Cabinet Resolution No. 134 of 2025.
Deliver comprehensive annual AML/CFT training for all staff, with bribery typologies, red flags, and STR reporting obligations explicitly covered. Senior management and board members should receive tailored briefings.
Conduct periodic reviews of correspondent and third-party relationships to identify the accumulation of bribery risk indicators over time, rather than evaluating each transaction in isolation.
Document MLRO deliberations and decisions, including cases where an STR was considered but not filed, so that supervisory reviews can trace the reasoning.

Anti-Bribery Compliance Checklist for UAE DNFBPs

EWRA includes bribery and corruption as standalone risk categories, anchored to the NRA and relevant SRAs
PEP screening applied at onboarding and continuously for all customers, UBOs, and related parties
EDD triggered for customers with PEP connections, high-risk sector activity, or high-risk jurisdictional exposure
Source of wealth and source of funds verified for all high-risk and PEP relationships
UBO identified and verified for all corporate and complex structure clients, with refresh at defined intervals
Procurement, contract management, and commission payment processes reviewed for kickback exposure
Transaction monitoring rules calibrated for inflated invoices, unexplained commissions, and structured cash
Whistle-blower policy in place with protected, confidential reporting channels aligned to Article 24 confidentiality rules
STR filed via goAML where bribery is suspected, regardless of transaction value or customer status
Annual staff training covers bribery typologies, red flags, STR filing, and confidentiality / no-disclosure obligations
MLRO decision log maintained, including no-file decisions with documented reasoning
Independent AML audit or health check conducted at least annually against Cabinet Resolution No. 134 of 2025

DNFBP Reporting Obligations: STRs and goAML

DNFBPs in the UAE are required to report bribery-related suspicious activity to the UAE Financial Intelligence Unit (FIU) through the goAML portal. This obligation applies immediately upon forming a suspicion. There is no minimum transaction threshold and no requirement that the suspicion be confirmed or the underlying bribery proven.

Failure to file an STR where bribery-related suspicious activity is identified is a breach of AML/CFT obligations under Federal Decree-Law No. 10 of 2025 and the Executive Regulations. Consequences may include administrative penalties under Cabinet Resolution No. 16 of 2021 (AED 50,000 to AED 1,000,000 per violation), supervisory action by MoET or the relevant authority, reputational damage, and potential criminal exposure for the MLRO and senior management.

The MLRO bears primary responsibility for STR decisions, including decisions not to file where the suspicion threshold is not met. Internal escalation protocols, documented consideration of available information, and a formal MLRO decision log are recommended practices, particularly for bribery-related matters involving PEPs or complex structures.

Once an STR has been filed, confidentiality and no-disclosure rules apply under Article 24 of Federal Decree-Law No. 10 of 2025 and Article 19 of Cabinet Resolution No. 134 of 2025. Disclosing to the customer or any third party that an STR has been filed, that related information has been shared with the FIU, or that an investigation is underway is prohibited, with penalties set out in Article 29 of the 2025 Law covering both intentional and grossly negligent disclosures. The MLRO and any other staff aware of the filing must handle subsequent customer interactions with particular care.

Strengthening AML Controls to Combat Bribery in the UAE

The UAE’s commitment to combating bribery and corruption is demonstrated through its comprehensive legislative framework, active FATF engagement, the supervisory mandate of MoET over DNFBPs, and the expanded enforcement powers of the FIU under the 2025 Law. There is an increasing regulatory expectation for Regulated Entities to integrate anti-bribery concepts explicitly within their AML/CFT frameworks, not as a generic predicate-offence footnote but as a core component of the EWRA, CDD, transaction monitoring, and training programme.

Entities that embed robust anti-bribery controls will not only fulfil their regulatory obligations but also build the institutional resilience needed to support sustainable growth in the UAE’s evolving compliance environment. The post-FATF grey list supervisory posture is materially more assertive than in earlier periods, and the margin for error under the 2025 Law is smaller.

Frequently Asked Questions

Bribery is the offering, giving, receiving, or soliciting of anything of value to influence the actions of an official or decision-maker, whether in the public or private sector. It is a FATF-designated predicate offence within the category of “corruption and bribery”. Any profit derived from bribery that is subsequently concealed, converted, transferred, acquired, possessed, or used triggers a separate money laundering offence under Federal Decree-Law No. 10 of 2025. Effective AML compliance requires incorporating anti-bribery controls across the EWRA, CDD, transaction monitoring, and training programme.

Corruption is the broader category encompassing abuse of entrusted power for private gain. Bribery is one specific form: the offering, giving, receiving, or soliciting of anything of value to influence a decision. A kickback is a further subset: a payment made after the transaction to the person who arranged or approved the deal, typically structured as a return of a portion of the contract value. All bribery constitutes corruption, but not all corruption involves bribery.

Bribery proceeds typically move through three stages. Placement involves introducing the funds into the financial system via cash deposits, structuring, or high-value asset purchases. Layering involves moving the funds through shell companies, offshore trusts, and complex ownership structures to obscure origin. Integration involves re-entering the legitimate economy through real estate acquisitions, corporate investments, or professional services. All three stages have significant DNFBP exposure in the UAE.

The primary instruments are Federal Decree-Law No. 31 of 2021 (the UAE Penal Code, Articles 275 to 287 covering public sector, foreign official, and private sector bribery); Federal Decree-Law No. 10 of 2025 (the AML/CFT/CPF Law); and Cabinet Resolution No. 134 of 2025 (the Executive Regulations). The UAE is also a signatory to UNCAC, ratified through Federal Decree No. 8 of 2006, and to the Arab Anti-Corruption Convention. Administrative AML penalties are governed by Cabinet Resolution No. 16 of 2021.

Private sector bribery under Articles 278 and 279 of the UAE Penal Code is punishable by imprisonment for up to five years, plus a fine equivalent to the value of the bribe and confiscation of the bribe itself. Public sector and foreign official bribery under Articles 275, 276, 280, and 281 carry temporary imprisonment, which under UAE penal law is a custodial sentence of between three and fifteen years. Intermediaries under Articles 282 and 283 face imprisonment for up to five years. Deportation may also be ordered.

Key red flags include: unexplained payments to agents and consultants; cash-intensive transactions without a verifiable source of funds; foreign PEP involvement without clear commercial justification; transactions routed through high-risk or offshore jurisdictions; inflated invoices, sham contracts, or unexplained commissions; complex structures obscuring the UBO; and customer reluctance to provide source of wealth or UBO information. These indicators should be calibrated in transaction monitoring and assessed cumulatively.

Yes, in substance. Under Cabinet Resolution No. 134 of 2025, DNFBPs must maintain AML/CFT/CPF policies and procedures addressing all relevant predicate offences, which include bribery. Supervisory expectation from MoET is increasingly that anti-bribery provisions are explicit rather than subsumed into a generic predicate-offence policy. A standalone anti-bribery and corruption (ABC) policy, or a clearly demarcated section within the AML/CFT policy, is considered best practice.

Yes. DNFBPs must report bribery-related suspicious activity immediately via the goAML portal, operated by the UAE FIU. There is no minimum transaction value. Failure to file constitutes a breach under Federal Decree-Law No. 10 of 2025, and may result in administrative penalties of AED 50,000 to AED 1,000,000 per violation under Cabinet Resolution No. 16 of 2021, plus potential criminal exposure for the MLRO and senior management. Once an STR is filed, the confidentiality and no-disclosure rules under Article 24 of the 2025 Law and Article 19 of Cabinet Resolution No. 134 of 2025 apply, with penalties set out in Article 29.

The Ministry of Economy and Tourism (MoET) supervises most DNFBP sub-sectors, including real estate agents and brokers, dealers in precious metals and stones, independent accountants and auditors, and corporate service providers. The Ministry of Justice (MoJ) supervises lawyers and notaries. Licensed financial institutions are supervised by the Central Bank of the UAE (CBUAE), and financial free zone entities are supervised by the DFSA (DIFC) or the FSRA (ADGM).

A predicate offence is the underlying crime whose proceeds may be laundered. Under Article 1 of Federal Decree-Law No. 10 of 2025, bribery is a predicate offence whether committed inside or outside the UAE, provided the conduct is punishable in both jurisdictions. This means that in addition to criminal liability for the bribery itself, any subsequent handling of bribery proceeds (concealment, conversion, transfer, acquisition, possession, or use) constitutes a separate money laundering offence. Under the 2025 Law, a conviction for the predicate offence is no longer required to prosecute the money laundering offence.

How AMLUAE Supports UAE DNFBPs with Bribery Risk Management

Many Regulated Entities fail to tailor their risk assessment and documentation to address bribery and corruption as standalone risk categories. Effective compliance depends on robust KYC and EDD processes that uncover true beneficial owners and intermediary risks, combined with transaction monitoring and training calibrated to UAE-specific bribery typologies.

AMLUAE provides end-to-end compliance support across the full AML/CFT/CPF lifecycle for UAE DNFBPs and financial institutions, including:

EWRA development and refresh, with bribery and corruption built in as standalone risk categories anchored to the NRA and SRAs
AML/CFT/CPF health checks and gap analysis against Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025
Policy, procedure, and work instruction drafting, including standalone anti-bribery and whistle-blower policies
Regulatory reporting support, including goAML STR preparation, filing, and supporting documentation
KYC, CDD, and EDD process review and enhancement for DNFBP and FI contexts
AML/CFT training programmes covering bribery typologies, red flags, STR filing, and the Article 24 confidentiality and no-disclosure obligations
MLRO advisory and outsourced MLRO support for regulated entities without an in-house function

Visit amluae.com or contact the AMLUAE team at amluae.com/contact-aml-uae/ to discuss your compliance support requirements. For training-specific enquiries, visit proamltraining.com.