AML Regulations for CMA-Regulated Forex Companies in UAE
Published On: 09/01/2026
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Last Reviewed On: 09/01/2026 | Last Updated On: 09/01/2026
Key Highlights: AML Compliance for UAE Forex Companies
- Retail margin forex brokers, contracts for difference and derivatives providers, online trading platforms and their introducing brokers all meet the definition of a financial institution set by Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
- The Capital Market Authority, created by Federal Decree-Law No. 32 of 2025, supervises AML and CFT and took over from the Securities and Commodities Authority. It is not the Central Bank, and a forex platform should not be mistaken for a licensed exchange house.
- Nationally, the securities sector carries a money laundering rating of medium to medium-high; its control environment is judged effective, and its proliferation financing exposure is graded low across the mainland and the financial free zones alike.
- For a margin desk, the danger clusters around fast retail sign-ups, the origin of money paid in as margin, quick card and payment-provider top-ups followed by equally quick withdrawals, the affiliates and introducers feeding the book, and matched or wash positions dressed up as trading.
- Layered above the federal statutes, the Capital Market Authority publishes its own rulebook chapter, sector guidance, notices, thematic findings and return formats, and a forex firm has to fold each of these into its compliance programme.
- Virtual assets and crypto derivatives are overseen by virtual assets regulatory authorities in the UAE under a distinct regime, not the securities rules described here, while any operator based in the DIFC or ADGM reports to the DFSA or FSRA and falls outside this guide.
A forex company supervised by the Capital Market Authority, whether it runs a retail margin desk, a contracts for difference book, a derivatives platform or an introducing-broker channel, sits squarely inside the federal AML net. It answers to Federal Decree-Law No. 10 of 2025, the Executive Regulations set out in Cabinet Resolution No. 134 of 2025, the sanctions obligations in Cabinet Decision No. 74 of 2020, mandatory goAML reporting to the UAE FIU, and the Capital Market Authority rulebook and reporting standards. Platforms licensed in the DIFC or ADGM instead answer to the DFSA and FSRA.
Forex companies live on speed and volume. They open retail trading accounts at scale, take deposits and pay out withdrawals in minutes, and offer leveraged exposure to currencies and other markets through margin and contracts for difference. That business model, with its high client turnover, fast money movement and heavy use of payment providers and introducers, gives them a money laundering profile all of their own. Because they deal in leveraged securities and derivatives rather than banknotes, they are supervised by the Capital Market Authority, not the Central Bank, and they should not be confused with the exchange houses the Central Bank licenses.
This guide sets out the AML regulations for CMA-regulated forex companies in the UAE: which firms are in scope, the regulator, the full legal framework, how the national risk assessments rate the securities sector, and the controls a margin trading business is expected to run. It covers CMA-licensed forex and margin trading firms outside the DIFC and ADGM.
Who is a Forex Company for AML Purposes?
For AML purposes, this category covers firms the Capital Market Authority licenses to offer foreign exchange and leveraged trading products to clients. The types below all fall under the AML regulations for CMA-regulated forex companies in the UAE. The DFSA and FSRA supervise firms established in the DIFC and ADGM, so they are not covered here.
Retail margin forex brokers
Retail margin forex brokers let clients trade currencies on leverage. Their exposure is heaviest at onboarding, in the source of the funds a client deposits as margin, and in how quickly money can move in and straight back out of a trading account.
Contracts for difference and derivatives providers
Contracts for difference and derivatives providers offer leveraged exposure to currencies, indices, commodities and shares without owning the underlying. Their risk sits in client due diligence, the funding behind large or rapid positions, and trading patterns that move value between accounts rather than seek genuine profit.
Online and electronic trading platforms
Online platforms onboard and serve clients remotely, often across borders and at high volume. Their controls centre on remote identity verification, payment provider and card flows, and monitoring for the rapid, round-trip funding that can signal layering.
Introducing brokers and white-label partners
Introducing brokers, affiliates and white-label partners bring clients to the platform, often for a commission. Their risk lies in the due diligence a firm performs on the introducer, the clients introduced from higher-risk markets, and bonus or rebate schemes that can be used to disguise the movement of funds.
AML Supervisory Authority for Forex Companies in UAE
Capital Market Authority (CMA): the AML Supervisor for UAE Forex Companies
The Capital Market Authority is the federal body responsible for the UAE securities and commodities sector. It was constituted by Federal Decree-Law No. 32 of 2025 to carry forward the mandate of the Securities and Commodities Authority. The CMA licenses any firm offering leveraged currency and derivative products to clients outside the DIFC and ADGM and holds it accountable for AML and CFT purposes. Through its rulebook chapter, sector guidance, notices and thematic findings, it shapes how these programmes are run, and it backs that up by collecting periodic AML returns, conducting on-site examinations and levying administrative fines where a firm falls short. For its supervisory guidance, a forex company looks to the Authority rather than the Central Bank and applies that rulebook alongside the federal AML statutes.
UAE FIU and goAML Reporting for Forex Companies
Each in-scope forex company must enrol with the UAE Financial Intelligence Unit and submit its reports electronically. Housed within the Central Bank under Federal Decree-Law No. 10 of 2025, the Unit receives suspicious transaction reports, suspicious activity reports, and any further filings the framework requires, and it may request more detail or share intelligence with supervisors and law enforcement. For a margin desk, the goAML portal is where a doubtful deposit, a same-day round-trip withdrawal, a client who trips a sanctions list, or an introducer channelling high-risk business is brought to the regulator’s attention. Enrolment, prompt filing and accurate submissions are legal obligations, and both the Authority and the Unit weigh how well a firm meets them.
AML Legal Framework Applicable to Forex Companies in UAE
For a CMA-regulated forex company, the rules stack up in four tiers: the federal AML statutes and their executive regulations, the guidance addressed to every reporting entity, the national and sector risk assessments, and the Authority’s own rulebook and sector material. These sit within the AML regulations for UAE capital market firms, and the instruments listed below are set out one by one, with a note on what each means for a margin forex or CFD operation in day-to-day terms.
Federal AML Laws and Executive Regulations Applicable to Forex Companies in UAE
These are the core federal instruments every forex company builds its programme on.
Federal Decree-Law No. 10 of 2025 on AML, CFT and CPF
A CMA-licensed forex firm opening retail margin accounts online builds its controls on Federal Decree-Law No. 10 of 2025, the base statute of the UAE anti-money laundering regime. It defines money laundering, predicate offences, terrorism financing, proliferation financing, and targeted financial sanctions, while establishing the framework for suspicious transaction reporting. The law creates the Financial Intelligence Unit inside the Central Bank as the national agency receiving suspicious transaction reports, able to seek information and, via the Head of the Unit, to direct suspension and freezing. For a margin or CFD provider, it means supervision, administrative fines, and a duty to spot, report and escalate suspicious dealings.
Cabinet Resolution No. 134 of 2025, the Executive Regulations
Cabinet Resolution No. 134 of 2025 issues the Executive Regulations of Federal Decree-Law No. 10 of 2025, turning the statute into the operating manual a retail forex firm follows daily. It widens the defined terms to include reasonable measures, wire transfers, senior management and the beneficial owner, and places currency dealing and funds transfers within scope. For a margin or CFD provider, it fixes the substantive duties: a risk-based approach, customer due diligence at high-velocity account opening, verification of the beneficial owners behind corporate and introduced clients, continuous monitoring of deposits, trades and withdrawals, and internal policies signed off by senior management. These procedures are exactly what examiners test.
Cabinet Decision No. 109 of 2023 on beneficial owner procedures
Corporate clients and white-label partners sit behind a natural person, and Cabinet Decision No. 109 of 2023 governs how that person is identified. It sets the beneficial owner procedures legal persons in the United Arab Emirates must follow, treating the real beneficiary as whoever ultimately owns or controls the entity, directly or through a chain of ownership. They must gather, keep and disclose accurate ownership data, identify nominee board members, and refresh the register within fifteen days of any change. A forex firm relies on it to verify corporate and partner accounts. These duties apply to legal persons in the State and commercial free zones, not the DIFC or ADGM.
Cabinet Resolution No. 132 of 2023 on penalties for beneficial owner violations
Cabinet Resolution No. 132 of 2023 supplies the enforcement behind the beneficial owner regime, fixing administrative sanctions for breaches of the procedures in Cabinet Decision No. 109 of 2023. A registrar can fine a legal person that keeps an inaccurate register or withholds required information, per an annexed schedule and without prejudice to any penalties or procedures under the AML Decree-Law and other applicable legislation. Penalties climb with repetition: a third breach lets the registrar suspend the licence and shut the premises until the fine is paid and the violation is remedied.
Cabinet Decision No. 74 of 2020 on terrorist lists and UNSC resolutions
Screening every retail applicant, deposit and withdrawal against the sanctions lists rests on Cabinet Decision No. 74 of 2020. It sets how the UAE gives effect to the terrorist lists and to United Nations Security Council sanctions covering terrorism, its financing and proliferation. A local Cabinet list is provided for; the decision names designation, listing and de-listing, then demands assets be frozen without delay, that is within twenty-four hours. For a margin or CFD provider, it anchors screening: firms register on the Executive Office website, continuously screen clients, prospective account holders, beneficial owners and payment counterparties, freezing confirmed matches without notice and reporting promptly to the supervisor.
Federal Law No. 7 of 2014 on combating terrorism crimes
The conduct a forex firm’s monitoring is built to catch is defined in Federal Law No. 7 of 2014 on Combating Terrorism Crimes, the UAE’s criminal statute on terrorism. It lays out concepts including terrorist person, terrorist organisation, terrorist purpose and terrorist crime, with penalties reaching life imprisonment and, in named cases, death. What matters most to a margin or CFD provider is terrorism financing: the law punishes providing, collecting or holding funds for terrorist ends and covers the freezing of suspect funds held at financial institutions. Since the framework defines terrorist acts by pointing to this statute, firms use it to read what their deposit and trade surveillance targets.
AML Guidance Applicable to All Reporting Entities
Over and above the primary legislation, the UAE Financial Intelligence Unit, the Executive Office for Control and Non-Proliferation and the various supervisors put out typologies and guidance meant for the whole population of reporting entities, forex platforms among them.
UAE FIU Regulation No. 1 of 2026 on Suspension and Freezing Powers, April 2026
When a client moves to pull margin from a trading account or wire a suspect deposit onward, UAE FIU Regulation No. 1 of 2026, dated April 2026, sets out how the flow is halted. Issued under the AML/CFT Decree-Law and its Executive Regulation, it deals with postponing or suspending suspicious transactions and freezing funds, and binds reporting entities alongside existing duties. It introduces the Postponement Suspicious Transaction Report, an urgent filing where funds tied to crime face imminent transfer, withdrawal or dissipation. Its Head may impose suspension up to ten working days and freezing up to thirty, giving a forex firm a fast-track tool to hold client deposits and margin.
UAE FIU Strategic Analysis Report on Human Trafficking, April 2026
The UAE FIU Strategic Analysis Report on Human Trafficking, dated April 2026, studies money laundering and financial flows linked to trafficking, drawing on the suspicious transaction and activity reports held by the Financial Intelligence Unit. It states its objectives, methodology and scope, runs through the main forms of exploitation, and reports on the laundering of proceeds and its overlap with other crime. It profiles subjects such as money mules, foreign politically exposed persons and organised crime groups, and frames risk indicators spanning due diligence, customer profile, behavioural activity and account and transactional activity. For a forex firm, it helps tune monitoring of rapid deposits and withdrawals.
Guidance on Targeted Financial Sanctions for Financial Institutions, DNFBPs and VASPs, March 2026
First published in January 2021 and last amended in March 2026, this Executive Office guidance sets out what the targeted financial sanctions framework requires of a forex company. A firm must sign up to the Executive Office’s Notification Alert System, keep its clients checked against the UAE Local Terrorist List and the United Nations Consolidated List, freeze on a match at once while never letting a designated person reach the money, and report what it does. The March 2026 revision renames the Funds Freeze Report as the Confirmed Name Match Report and addresses weekend screening, which matters where a platform accepts deposits and processes withdrawals around the clock. For a margin broker, it defines how screening, freezing and reporting run.
Joint Guidance on the Compliance Officer and MLRO, 2026
A forex firm moving fast on retail onboarding needs a compliance officer with real authority, and this 2026 joint guidance from the UAE Supervisory Sub-Committee sets a single framework for the role. It addresses the appointment, powers and duties of the Compliance Officer or Money Laundering Reporting Officer across regulated sectors, reaching firms supervised by the Capital Market Authority, the Central Bank and the Ministries of Justice and of Economy and Tourism, and builds on Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025. It treats the role as central, requiring seniority, experience, independence, board access and resources.
FIU Strategic Analysis Report on Terrorist Financing, May 2025
Published in May 2025 by the UAE Financial Intelligence Unit, this strategic analysis of terrorist financing typologies and facilitators rests on data held between 1 January 2021 and 31 December 2024, including suspicious transaction and activity reports and cases passed to authorities. It explains how terrorist financing operates and maps typologies such as moving and hiding funds through corporate networks, financial institutions, high-value goods, real estate and trade-based methods. It also looks at facilitators, from designated persons and family members to money mules, corporate nominees and professional service providers, ending with practical indicators. For a forex firm, these indicators sharpen detection and reporting across margin accounts and payment flows.
Federal Decree-Law No. 6 of 2025 on the Central Bank (regulatory background)
Federal Decree-Law No. 6 of 2025 is the Central Bank law covering the licensing and supervision of financial institutions. It is not the anti-money laundering statute, yet it sits in the surrounding framework because it supports the broader financial system a forex firm relies on daily, from the card acquirers and payment service providers that move client deposits to the settlement banks behind them. For a CMA-licensed margin or CFD provider, it matters mainly at the perimeter: knowing which counterparties and payment partners hold Central Bank licences, and how the CMA regime under Federal Decree-Law No. 32 of 2025 and the Central Bank regime interlock.
goAML FAQs, April 2024
Version 2.1 of the goAML FAQs, dated 18 April 2024, is the Financial Intelligence Unit’s practical question-and-answer note for reporting entities using goAML and its registration and access services. It works through the usual registration and login problems with step-by-step fixes, from one-time passwords that expire at first login, to pop-up authentication that expects the system-issued username with a Google Authenticator code, to the correct login order and resetting a forgotten password. It says where credentials belong and who to contact when errors persist. For a forex firm, dependable goAML access is what keeps a suspicious transaction report moving to deadline, so the note keeps compliance teams connected.
PF Institutional Risk Assessment Guidance for FIs, DNFBPs and VASPs, December 2023
Published in December 2023, this guidance shows a firm how to gauge and manage its exposure to proliferation financing. It describes a methodology resting on residual risk, control effectiveness and inherent risk, then names the categories and factors a firm weighs when scoring its business. It runs through supporting measures, spanning suspicious activity reporting, transaction and ongoing monitoring, sanctions and adverse-media screening, enhanced due diligence, and onboarding with know your customer checks. A customer risk-scoring questionnaire, elevated risk factors and worked case studies show how the scores land. For a forex firm, it turns proliferation financing duties into a repeatable framework a supervisor can review.
Terrorist and Proliferation Financing Red Flags Guidance, December 2023
Updated in December 2023, the Terrorist and Proliferation Financing Red Flags Guidance collects indicators that help a firm flag suspicious financing and attempts to evade targeted financial sanctions under United Nations resolutions or local designations. It shows how sanctioned parties bury their involvement through renaming, intermediaries and front companies, which matters when a forex firm screens the beneficial owners behind corporate and white-label accounts. The indicators are grouped by trade finance, maritime, transaction activity, account and customer profile. For a margin or CFD provider, it sharpens both the front line and compliance, guiding the call on when account or payment activity should trigger a report.
Suspicious Activity and Transaction Reporting Thematic Review, January 2023
This January 2023 thematic review pulls the main findings and expectations out of the 2022 AML and CFT examination of licensed financial institutions and DNFBPs. Its focus is the suspicious transaction and activity reporting framework and the monitoring systems that feed it, read with the existing guidance on reporting, monitoring and screening. Structured around expectations, it sets acceptable against deficient practice across governance, policies, risk-based monitoring, data management, alert review, case investigation, reporting decisions and the post-reporting process.
Counter Proliferation Financing Guideline, November 2022
Issued in November 2022 by the Executive Office for Control and Non-Proliferation, this guideline sits alongside the wider targeted financial sanctions guidance and lifts awareness of proliferation financing among regulated firms. It defines proliferation financing, walks through its stages, and describes the UAE counter-proliferation framework, the interagency mechanism and the governing federal laws. For a margin forex or CFD provider, it explains how to fold proliferation financing risk into the firm’s own risk assessment and respond with mitigating measures: enhanced due diligence on clients and transactions, attention to shell and front companies, alertness to dual-use trade exposure, and staff training. Its red flags help spot attempted sanctions evasion through trading accounts.
goAML Web Submission Guide, July 2022
Issued by the UAE Financial Intelligence Unit in July 2022, the goAML Web Submission Guide explains how a report reaches the FIU through the goAML platform. It is aimed at the Compliance Officer or Money Laundering Reporting Officer of a registered reporting entity, or their deputy when the lead officer is unavailable. It surveys the report types, from the Suspicious Transaction Report and Suspicious Activity Report, the latter covering suspected activity or an attempted deposit or trade that never executed, to the Additional Information File, Request for Information and High Risk Country reports. For a forex firm, it standardises how a suspicion around an account or payment is filed promptly.
Joint Guidance on Combating the Use of Unlicensed Virtual Asset Providers, March 2022
Providers operating outside the licensing regime are the target of this March 2022 joint guidance from the UAE Supervisory Authorities, the Capital Market Authority and the Central Bank among them. It restates regulated firms’ AML duties and urges the public to deal only with licensed entities. Firms are expected to stay alert, feed emerging risks into their assessments, run proper due diligence, flag clients drawn to unlicensed providers, and report suspicions. The red flags include no licence, no physical presence, unrealistic promises or Ponzi structures, and pressure to invest quickly. For a margin trading firm, it tightens scrutiny of client funding that brushes against unlicensed virtual-asset activity.
IEMS User Guide for Reporting Entities, March 2022
The Integrated Enquiry Management System automates information requests, the implementation of public prosecution decisions and other demands from domestic authorities, and this March 2022 Financial Intelligence Unit manual explains how a firm uses it. Firms already on goAML sign in with the same credentials. It runs through the dashboard, request management and the workflow for replies and attachments, from the details of an account, its holder and any signatory through to the three user roles of Admin, Maker and Checker, and it presses firms to meet due dates and to act on a freeze order at once. For a forex company, it shows how an authority’s enquiry into a client or trading account is received, worked and answered on time.
goAML Pre-Registration Guide, March 2022
Before a forex firm can register on goAML or file a report, it needs access to the Services Access Control Manager, and this March 2022 Financial Intelligence Unit guide explains how to obtain it. Entities not regulated by the Central Bank apply through a public portal, while others follow their Supervisory Body’s route. The Access Control Manager holds the links to the production and testing environments and is protected by a time-based one-time password from Google Authenticator. The guide covers pre-registration, confirming intent and safeguarding a personal Secret Key. For a margin trading business, getting this step right is the precondition for secure, reliable reporting access.
goAML Registration Guide, March 2022
The goAML Registration Guide, issued by the UAE Financial Intelligence Unit in March 2022, lays out the steps an organisation takes to register with the FIU on its reporting platform. It applies to registration as a reporting entity, stakeholder or supervisory body, and states that every accountable and reporting entity in the country, regardless of regulator, must register to file suspicious reports. It maps the route to the portal via the Services Access Control Manager, then selecting a registration type, keying in the organisation and addresses, naming the registering person and assigning user rights. For a forex firm, sound registration is the base for compliant, timely reporting.
Strategic Review on Targeted Financial Sanctions Case Studies, November 2021
Dated November 2021, this Strategic Review on Targeted Financial Sanctions Case Studies reviews how sanctions reporting worked in the UAE over the period. It sits inside the framework by which the country, through Cabinet Resolution No. 74 of 2020, applies United Nations Security Council Resolutions on terrorism, its financing and proliferation, with freezing and bans on making funds and services available. The review explains its method, then classifies the reports by source, suspicion and the instruments at play, drawing out patterns separating terrorist from proliferation financing, with red flags and recommendations. For a forex firm, it shows how a sanctions suspicion around a client or deposit arises and is reported.
Strategic Review on Targeted Financial Sanctions Case Studies, April 2024
The review provides practical lessons drawn from real UAE sanctions cases between 2019 and 2023. Rather than introducing new legal obligations, it highlights how sanctions controls succeed or fail in practice and the supervisory expectations that follow. For forex firms, the Review serves as a valuable resource for strengthening sanctions screening, customer due diligence, payment monitoring, escalation procedures, and the detection of sanctions evasion techniques. It encourages firms to test whether their controls can identify higher-risk customers, complex ownership structures, unusual funding patterns, and attempts to circumvent targeted financial sanctions, helping ensure that their sanctions framework is effective in practice rather than simply compliant on paper.
Typologies on the Circumvention of Targeted Sanctions, November 2021
For a margin trading firm, the value in this November 2021 Executive Office report is its catalogue of evasion. It gathers real cases, taken from UAE and international public sources, of how designated persons and entities try to slip past targeted financial sanctions tied to terrorism and weapons proliferation, defeating United Nations resolutions and the national terrorist list. The methods are grouped by channel: online payment facilities, dual-use goods trade, layered corporate structures, cyber activity and economic resources, each with named networks and red flags. A forex broker can test these against its own deposit, withdrawal and introducer channels to sharpen screening and monitoring.
Update to the List of High Risk Jurisdictions, November 2021
This November 2021 decision of the National Anti-Money Laundering Committee updates which high-risk jurisdictions face a call for action, which sit under increased monitoring, and the counter-measures to apply, replacing a March 2021 decision. Addressed to the supervisory authorities and the Financial Intelligence Unit, it carries the Committee’s remit to identify weakly controlled countries, set proportionate counter-measures and require supervisors to enforce due diligence. For a forex firm, country risk is a core input to controls, signalling which jurisdictions call for enhanced due diligence on offshore and remote clients and requiring risk assessments to track the latest listings.
Joint Guidance on Satisfactory and Unsatisfactory Practice, June 2021
Drawing on inspection themes from January 2020 to May 2021, this June 2021 joint guidance from the UAE Supervisory Authorities, among them the Capital Market Authority, the Central Bank and the Ministries of Justice and of Economy and Tourism, contrasts satisfactory with unsatisfactory practice across the AML framework, targeted financial sanctions and counter-proliferation financing. It runs from governance and management oversight, risk assessment, the three lines of defence, policies, training and the compliance officer role, through onboarding, monitoring, risk rating, due diligence, transaction monitoring, sanctions screening and reporting. For a margin forex firm, it is a benchmark to test controls over high-velocity retail accounts against real examples before an examiner does.
Typologies on the Circumvention of TFS, PF and WMD, May 2021
Last revised in May 2021 and published by the Executive Office, this typologies report looks at how sanctioned persons and entities raise money in breach or evasion of United Nations resolutions on terrorism and weapons proliferation. It stresses that targeted financial sanctions cover both freezing assets and the ban on making funds available, directly or indirectly, to sanctioned parties. Arranged by financing method, it runs through trade in goods, economic resources, online payment facilities, cyberattacks on financial institutions and the abuse of legal entities and arrangements, ending with red flags. For a forex or CFD firm, it reinforces the screening, monitoring and reporting of circumvention attempts routed through trading accounts.
goAML FAQs, September 2020
The goAML FAQs Guide, issued by the UAE Financial Intelligence Unit in September 2020, gives reporting entities a practical question-and-answer reference for the goAML platform, the channel through which suspicious reports are filed nationally. It collects the queries most often raised once an organisation is registered and live, each with a step-by-step answer. It walks through resetting a forgotten password, revising organisation details like name, licensed activity, address and contacts, and how the Money Laundering Reporting Officer, as admin, may hand reporting to a third party with Supervisory Body approval. For a forex firm, accurate registration data and managed access keep FIU reporting compliant and uninterrupted.
goAML Registration Guide Stage 2, September 2020
The goAML Registration Guide Stage 2, issued by the UAE Financial Intelligence Unit in September 2020, takes an organisation through registering with the FIU on its reporting platform. It governs sign-up as a reporting entity, stakeholder or supervisory body, and confirms that every accountable and reporting entity nationally must register to file suspicious reports, adding that since 27 June 2019, filing must be electronic through goAML. It sets out reaching the portal via the Services Access Control Manager, picking the registration type and registering the organisation. For a forex firm, proper registration is the gateway to lawful electronic reporting.
Guideline on Grievance Procedures
Issued by the Executive Office for Control and Non-Proliferation, the authority that receives grievance requests tied to the UAE Local Terrorist List and the United Nations Consolidated List, together the Sanctions Lists, this guideline explains the routes open to an affected party. Under Cabinet Resolution No. 74 of 2020, it deals with three: de-listing a designation, cancelling freezing measures, and permission to use frozen assets, each turning on whether the name sits on the Local or the United Nations list. For a forex company that has frozen a client’s balance on a sanctions match, it maps the lawful ways that client can challenge the designation or seek access to the funds.
Online Grievance System User Guide
Also from the Executive Office for Control and Non-Proliferation, which handles grievance requests linked to the two Sanctions Lists, this manual explains the online system built to streamline those submissions. It covers the same three request types: de-listing, cancelling freezing measures, and permission to use frozen funds, and takes the user step by step: identifying the aggrieved individual or entity, selecting the grievance type, declaring any earlier requests and appeals, and attaching supporting documents. For a forex company holding a client’s frozen trading balance, it shows the practical path that the client follows to contest a designation or ask to access the funds.
Simple Guide to Subscribe to the EOCN Notification Alert System (NAS)
A screening control is only current if the lists behind it are, and this short Executive Office guide explains how to keep them so. It walks a firm through subscribing to the Notification Alert System on the Executive Office website, so updates to the two Sanctions Lists, the UAE Local Terrorist List issued by the Cabinet and the United Nations Consolidated List issued by the Security Council, arrive promptly. It shows where each list lives and gives step-by-step subscription instructions, from the webpage through entering details to confirmation. For a forex company screening a fast stream of new retail accounts and payouts, this keeps that screening working against the latest designations.
Emerging ML, TF and PF Risks and Trends in the Financial Sector
Issued by the Supervisory Subcommittee under Article 16 of Federal Decree-Law No. 10 of 2025, this report offers regulated firms a present-day view of the terrorist financing, proliferation financing and money laundering threats reshaping the sector as technology, geopolitics and criminal methods change. After setting scope and methodology, it reviews emerging risks including artificial-intelligence exploitation, greenwashing and ESG-related fraud, trade-finance abuse, and sanctions evasion linked to the Commonwealth of Independent States. Its case studies run to fraudulent green schemes, free-zone corporate structures, trade-based laundering and money mule networks. A forex firm should feed these typologies and red flags into its risk assessments and monitoring of accounts and payments.
Typologies in the Financial Sector
Produced jointly by the Supervisory Authorities Sub-Committee and the Financial Intelligence Unit, with the Executive Office, this report shares typologies of money laundering, terrorist financing, sanctions abuse, fraud and corruption seen in the market, several emerging during the COVID-19 period. It sits above the National Risk Assessment and describes how risk indicators combine to disguise the real nature of transactions, with links flagged to modern slavery and human trafficking. For a forex or CFD provider, it works as an early warning: a prompt to refresh the risk assessment, tune monitoring scenarios for rapid deposits and withdrawals, and engage the authorities where patterns match.
UAE Virtual Assets Travel Rule
The UAE Virtual Assets Travel Rule binds virtual asset service providers at federal, emirate and free-zone level, and it requires originator and beneficiary details to accompany every virtual-asset transfer. A forex company that offers crypto-linked instruments, advises on them, or holds virtual assets for clients turns to it to learn what data must ride with a transfer and what risk-based and enhanced due diligence the movement demands. It brings the UAE into step with the FATF travel-rule standard and governs how a leveraged-trading business records and screens the virtual-asset flows passing through client wallets and funding routes.
NRA, SRA, and Other Important Guidelines for Forex Companies in UAE
The UAE assesses its money laundering, terrorist financing and proliferation financing risk at the national level, and forex companies must align their business-wide and enterprise-wide risk assessments with those findings.
UAE PF National Risk Assessment 2026
The UAE Proliferation Financing National Risk Assessment 2026 looks at how far the country is exposed to funding for weapons of mass destruction and to attempts at dodging the targeted financial sanctions imposed under the United Nations measures against North Korea and Iran. Drawn up to answer the Financial Action Task Force revised Recommendation 1, it grades the securities sector low for proliferation financing across both the mainland and the financial free zones, while putting the country as a whole at medium-high. For a forex firm, it pinpoints where that exposure gathers and signals how client screening and scrutiny of deposit funding ought to react.
UAE ML and TF National Risk Assessment 2024
The UAE Money Laundering and Terrorist Financing National Risk Assessment 2024 is the second exercise of its kind, built on the World Bank methodology and resting on figures gathered between 2019 and 2023. It puts the securities sector residual money laundering risk at medium to medium-high, a reflection of the wide spread of activity it captures, yet records that the sector control environment is judged effective. Its reach takes in the mainland and the financial free zones together. For a forex or CFD operator, it fixes the starting point that a risk-based programme should be built around.
The residual ratings a forex company should carry across into its own assessment are drawn together in the table that follows.
| Capital market (securities) sector residual risk | Rating |
| Money laundering and terrorist financing (NRA 2024) | Medium to medium-high, with the sector’s AML controls assessed as effective |
| Proliferation financing (PF NRA 2026) | Low in both the mainland and the financial free zones |
Beyond the national picture, sector risk assessments, red flag material and published typologies hand forex companies the granular detail that keeps Business Risk Assessment at enterprise level both up to date and able to withstand challenge.
CMA-Regulated Forex Sector-Specific Guidance
Above the federal baseline, the Authority issues the rulebook chapter, guidance, notices, thematic findings, and return formats that a forex company works with directly. The items below make up that sector-specific tier.
Federal Decree-Law No. 32 of 2025 on the Capital Market Authority
A margin forex or CFD provider in the UAE does not report to the Central Bank; its licensing supervisor is the Capital Market Authority, brought into being by Federal Decree-Law No. 32 of 2025. The statute makes the body heir to the Securities and Commodities Authority and the federal regulator for securities, exchanges, central clearing and depository institutions operating in the mainland and commercial free zones, though not the Financial Free Zones. The categories Licensed Persons, Approved Persons and Self-Regulatory Organisations are defined, with objectives spanning investor protection, market integrity and systemic-risk control. Article 5 confers the licensing, supervision, inspection, rule-making and sanctioning powers reaching leveraged-trading firms.
Federal Decree-Law No. 33 of 2025 on the Regulation of the Capital Market
Where Federal Decree-Law No. 32 of 2025 builds the regulator, Federal Decree-Law No. 33 of 2025 supplies the operative rulebook for capital market activity, governing the forex and derivatives business directly. Article 3 enumerates the licensable financial activities: dealing, asset management, custody, running an investment fund, advisory work, and operating a market or a clearing and depository system. Carrying on any of these, or acting in an approved function, without authorisation is barred. The law defines the securities, issuers, foreign issuers, investment funds, insiders and inside information it regulates, curbs insider dealing through prohibited dealing periods, and sets out the settlement, restructuring or liquidation of a Licensed Person.
CMA Key AML/CFT/CPF Obligations, Risks and Supervisory Observations, 2025
This 2025 letter from the Capital Market Authority reaches the Chief Executive Officers of licensed firms and catalogues the AML, CFT and CPF duties, emerging risks and supervisory findings a forex business must address. During its 2025 cycle, the Authority scored every firm’s inherent money-laundering, proliferation-financing and terrorist-financing exposure, weighing firm nature, scale, product mix, client base, delivery channels and geography against the FATF Recommendations and the National Risk Assessment. Onsite visits, MLRO report reviews, desk work and thematic exercises surfaced repeat weaknesses for board-level remediation. Margin providers should track suspicious-reporting trends, sanctions-screening results and beneficial-ownership records, alert to Article 17 enforcement.
CMA Instructions for the 2024 Annual Return AML/CFT and TFS Risk Assessment
A CMA-licensed forex company files this yearly return covering AML, CFT and targeted financial sanctions, and the instructions prescribe how. Reporting spreads across five tabs: customer risk, product and service risk, distribution-channel risk, signatories, and the controls and quality of mitigation. The Authority demands complete entries, figures stated in dirhams, and country data given in standard names or codes. Inherent risk is captured from the clients behind trading accounts, the securities and derivatives business, correspondent links, payment forms such as cards and payment service providers, and onboarding channels, then set against controls for enhanced due diligence, the compliance officer, trade monitoring, sanctions screening and internal audit.
CBUAE AML and CFT Guidelines for Financial Institutions, July 2023
The Capital Market Authority directs its licensees to these July 2023 Central Bank guidelines for the detail behind its expectations, even though the Central Bank, not the CMA, issued them. They walk through the risk-based approach and a business-wide risk assessment spanning customer, product, geographic and delivery-channel factors, and mitigation via internal controls and client due diligence, taking in beneficial-owner identification, the handling of wire transfers and continuous monitoring. For a margin forex firm, they turn typologies, statutory duties and reporting into workable benchmarks for onboarding retail accounts, screening every counterparty and monitoring deposit and withdrawal flows.
CMA Minimum Standards for the Semi-Annual AML and CTF Report, 2023
These 2023 minimum standards shape the semi-annual reports a forex firm’s Compliance Officer and Money Laundering Reporting Officer must deliver. Each firm prepares bi-annual reports for the periods closing 30 June and 31 December, has the board review them, and lodges the report, with the Board’s remarks, at the Capital Market Authority within two months of each period’s close. The order runs from an executive summary into governance, then the enterprise-wide risk assessment, customer risk rating and due diligence, the firm’s policies, before a gap analysis, an action plan, the findings and final board sign-off.
CMA Implementation of Targeted Financial Sanctions, May 2022
Under CMA Notice 1/2022 of 19 May 2022, every licensee must apply targeted financial sanctions imposed through UN Security Council Resolutions 1718 (2006) and 2231 (2015), in line with Cabinet Resolution No. 74 of 2020. A forex or CFD provider screens each party to a financial transaction, adds enhanced due diligence where dealings touch relevant countries, and checks cross-border margin and settlement flows for suspected unauthorised trade in dual-use goods. Any confirmed match triggers a Confirmed Name Match Report through goAML inside five working days, a potential match the Partial Name Match Report, and suspect activity an STR reaching the Financial Intelligence Unit. Firms follow Executive Office guidance and block evasion.
CMA Thematic Review on Reliance on Third Parties, December 2021
Reliance on third parties matters to any forex firm using introducing brokers, white-label partners or outsourced onboarding, and this second CMA thematic review of December 2021 tested that discipline against FATF Recommendation 17. Its subjects were the five firms then licensed for custody of securities, each a bank or local branch of a foreign bank with a Central Bank licence. A twenty-one-question survey met a full hundred per cent response: four of the five used third parties, two inside their group and two outside, each regulated or listed and under service level agreements. Specialist skills, cost and technology were the reasons, yet ultimate due diligence responsibility remains the custodian’s.
CMA Thematic Review of Targeted Financial Sanctions in the Capital Market Sector, November 2021
Rated medium-high for vulnerability in the National Risk Assessment, forex and securities brokers are a prime entry point for value, so this November 2021 CMA thematic review probed how brokerage firms grasp and apply targeted financial sanctions, both international and domestic, under Cabinet Resolution No. 74 of 2020. A twenty-nine-question survey returned a ninety-six per cent response. Sixty-five per cent maintained standalone sanctions risk assessments, seventy per cent ran third-party screening systems, while eighty-one per cent screened each day; a single firm identified, escalated and froze one match during 2021. Strong practice ran to senior-management sign-off, checking vendor coverage of domestic lists, defined reporting lines and Executive Office monitoring.
CMA AML and CFT Guidance for the Capital Market Sector, September 2021
Issued in September 2021 as a supplement to the main Financial Institutions Guidelines, this guidance records what the Capital Market Authority expects of the firms it licenses, to be read together with those broader guidelines. It speaks to the boards, managers and employees of any business carrying on securities activity in the UAE. Part 1 surveys the sector’s typologies, among them trade-based laundering via mis-invoicing and misstated price, quantity or quality, alongside cash-based laundering, with red-flag indicators throughout. Parts 2 and 3 develop the risk-based approach and the business-wide risk assessment, plus the customer, product, geographical and delivery-channel risk factors a firm must identify, assess and mitigate.
CMA Notice 3/2021 on the Immediate Reporting Mechanism
Notice 3/2021, dated 26 July 2021, reached every licensed entity and each licensed securities and commodities exchange to explain the immediate reporting mechanism for firms giving effect to Cabinet Resolution No. 74 of 2020 on terrorism-list regulation and the UN Security Council Resolutions against terrorism, its financing and the spread of weapons of mass destruction. Invoking Article 21, clause 5, it reported a fresh goAML feature routing details of matched names and the action taken straight to the Executive Office for goods under import and export control. A margin forex provider must rewrite its procedures and operate the mechanism accordingly.
CMA Notice 4/2021 on Targeted Financial Sanctions Reporting
Following the 26 July notice, Notice 4/2021 of 4 August 2021 reached all licensed entities and exchanges on sanctions reporting. Under Cabinet Resolution No. 74 of 2020, the Central Bank, working with the Executive Office of the Committee for goods subject to import and export control, built one mechanism on the FIU’s goAML platform. Two filings followed: the Funds Freeze Report, where a match is confirmed and frozen within two working days, and the Partial Name Match Report, where a match is potential, which calls for suspension. A forex firm reports simultaneously to both. These predate the March 2026 guidance, so live filings now use the renamed Confirmed Name Match Report.
CMA Notice 6/2021 on the Update to High Risk Jurisdictions
Dated 22 November 2021 and superseding Notice 1/2021, CMA Notice 6/2021 updates the National Committee’s lists of High Risk Jurisdictions subject to a Call for Action and Jurisdictions under Increased Monitoring, binding all licensed entities and exchanges. A forex firm onboarding remote and offshore clients must apply enhanced due diligence to any relationship or transaction reaching a listed country, take up the Recommendation 19 countermeasures against the Black List, and rescore each trader’s geographic risk. Reliance on third parties seated in Black List jurisdictions is barred; the firm files High Risk Jurisdiction reports through goAML and revisits its measures, proportionate to account risk, whenever a country is delisted.
SCA Board Chairman's Decision No. 21 of 2019 on AML and CFT Procedures
The SCA Board Chairman’s Decision No. 21/Chairman of 2019, signed by Sultan bin Saeed Al Mansouri, took effect on 7 May 2019 and issued on 8 May, carrying anti-money-laundering, terrorism-financing and illegal-organisation-financing procedures into the capital market. It bound every firm the Capital Market Authority licensed or approved, and its stakeholders, to Federal Decree-Law No. 20 of 2018, its executive regulation in Cabinet Decision No. 10 of 2019, and the Authority’s own rules. The regulator could inspect a forex firm unannounced and impose penalties. Those 2018 and 2019 references now read in light of Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
CMA Guidelines for Combating Money Laundering and Terrorist Financing (Chapter Five)
Chapter Five of the CMA rulebook holds the Guidelines for Combating Money Laundering, Counter-Terrorism Financing and Funding of Illegal Organisations. Its mandatory standards require each supervised firm to construct a compliance programme fitted to its risk profile. It sets out what a suspicious transaction, an ultimate beneficial owner and targeted financial sanctions are, steering firms to a risk-based approach weighted to higher-risk offshore margin traders. It fixes board responsibility, treats suspicious-activity reporting as a legal duty, and covers screening, record-keeping and training.
CMA AML and Financial Crimes Framework and Controls: Good and Weak Practices
This presentation from Mendy Ghaleb of the Capital Market Authority’s AML and Financial Crimes Department contrasts good practice with the failings inspectors most often meet in frameworks and controls. Its authorities are Federal Decree-Law No. 10 of 2025, Cabinet Resolution No. 134 of 2025, the sanctions, terrorism-list and beneficial-owner decisions, and Chapter 5 of the CMA Rulebook. From field visits and desk analysis, it flags recurring problems at forex firms: a generic business-wide risk assessment ignoring the leveraged-trading model, boilerplate risk-appetite statements carrying no thresholds, and cut-and-paste policies with scant board scrutiny. Article 17 lets it warn, fine up to AED 5,000,000, ban firms and revoke licences.
CMA Obligations to Implement the Business-Wide Risk Assessment (BWRA)
For a forex company, the Capital Market Authority frames the Business-Wide Risk Assessment as a strategic foundation of a working AML and CFT programme. The BWRA obliges the firm to identify, understand and gauge the whole span of money-laundering, terrorist-financing, sanctions and proliferation-financing risk it faces, looking across client types, products such as margin forex and CFDs, delivery channels, geographies and emerging technology. It proceeds in three stages: planning and scoping across legal entities, business units, divisions and regions; execution, measuring inherent risk from real data and building controls; and results, which pin residual risk to the firm’s risk-appetite statement and its action plans. It must stay live and current.
CMA Thematic Review of Screening Systems
Under Federal Decree-Law No. 10 of 2025 and the FATF standards, this horizontal, market-wide CMA review tested name and transaction screening throughout the UAE capital market. It ran forty-six screening systems through their paces across twenty-six Licensed Financial Institutions, with clean, control and variation datasets built on the United Nations and UAE sanctions lists. Screening is firmly bedded into onboarding and monitoring and caught obvious matches, yet it slipped on harder cases such as spelling variants and Arabic-Latin transliteration. Heavy alert volumes pointed to tuning work. The Authority expects calibration, governance, management information, metrics like the false positive rate, and steady optimisation.
CMA Questions and Answers on the National Risk Assessment
This CMA question-and-answer set shows how to line up its Enterprise-Wide Risk Assessment against the 2024 National Risk Assessment. The firm must translate the NRA’s typologies into its own book, for instance onboarding offshore special purpose vehicles, moving value through matched or wash trades, thin beneficial-owner documentation, and the abuse of nominee arrangements and shell companies. Even a low-risk firm must read the NRA, record its relevance and reassess yearly. The Authority wants a documented trail: a dated fresh assessment, updated screening, onboarding and third-party reliance policies, training records, board minutes and a gap analysis, with changes carried into the annual AML Return and evidence of delivery.
CMA Circular on the Examination Observations Report
Built on the annual AML/CFT and TFS risk assessment returns, this CMA circular reports what examinations found when the returns were judged on a risk-based basis. Recurring gaps stood out: stale governance policies, feeble testing of sanctions controls, thin risk assessments, shortfalls in customer due diligence and in grasping who really owns the accounts, sanctions programmes lacking the eight essential components, and weak suspicious-transaction handling. A forex firm should remediate, pull in the board and auditors, and keep oversight. Failure can bring penalties from AED 50,000 to AED 5,000,000 for each violation and loss of licence.
CMA Chapter Five Outreach
Chapter Five Outreach unpacks the Authority’s Chapter Five Regulations on combating money laundering, financing terrorism and bankrolling illicit organisations. It takes a forex firm step by step through the mandatory standards, their roots in federal AML law, and the way the CMA expects them to be applied in day-to-day margin and CFD business. As a companion to the binding Chapter Five Regulations, it serves as a practical reference for implementing customer due diligence, risk assessment, transaction monitoring, sanctions compliance and suspicious transaction reporting across CMA-regulated firms. It puts the rulebook chapter into language a compliance team can act on quickly.
CMA and FIU Joint Awareness Session on Suspicious Reporting Effectiveness
The session recaps the governing legislation, the responsibilities financial institutions carry, and the governance and internal controls it wants to see, then bears down on quality: lodging full, prompt and reasoned suspicious transaction and activity reports over goAML instead of defensive, low-value filings. For a margin provider, it reinforces the importance of strong customer due diligence, effective transaction monitoring, clear escalation procedures and high-quality reporting supported by adequate evidence and documentation.
CMA Examination Observations, Appendix of Detailed Findings
Sitting behind the headline examination observations of the CMA, this appendix collects the granular findings the summary leaves out. Topic by topic, it logs the weaker and stronger practices inspectors recorded at capital market firms, spanning governance, risk assessment, sanctions screening and reporting. A forex company can treat it as a ready-made self-check: measured against its own programme, it exposes the precise control weaknesses the regulator has already sanctioned in the sector, from a shallow business-wide risk assessment to a screening set-up that misses domestic listings or reporting that arrives late and thin.
Core AML/CFT Compliance Obligations for UAE Forex Companies at a Glance
A CMA-regulated forex company is expected to operate a full risk-based AML programme proportionate to its business. The ten obligations below are the ones the Capital Market Authority tests on examination.
Business-wide risk assessment. A BWRA that mirrors the firm’s products, client base, delivery channels, and introducers, kept live as the business changes.
Customer due diligence. CDD at account opening that meets UAE KYC requirements, with dependable remote identity verification, enhanced due diligence for higher-risk clients, and identification of the beneficial owners standing behind corporate and introduced accounts.
Source of funds and source of wealth. Establishing and testing where a client’s margin funds have come from and understanding source of wealth where the risk profile requires it.
Ongoing transaction monitoring. Continuous monitoring of deposits, withdrawals and trading activity for round-trip movement, matched or wash positions, and funding patterns inconsistent with the client profile.
Targeted financial sanctions. Continuous sanctions screening of clients, prospective clients, beneficial owners and payment counterparties against the UAE Local Terrorist List, the United Nations Consolidated List and any other applicable lists, with an immediate freeze and report on a confirmed match.
Introducer and third-party due diligence. Due diligence on introducing brokers, affiliates and white-label partners, with ultimate responsibility for customer due diligence remaining with the firm.
Governance and the MLRO. A competent Compliance Officer and Money Laundering Reporting Officer with the seniority, independence, board access and resources the role requires.
goAML reporting. Suspicious transaction and suspicious activity reporting through goAML without tipping off, alongside the sanctions filings the framework requires.
Record keeping and training. Retention of customer due diligence and transaction records, and periodic AML/CFT training for staff and the board.
Periodic returns to the Authority. The annual AML/CFT and targeted financial sanctions risk assessment return, and the semi-annual AML and CTF report lodged with the Capital Market Authority within two months of each period closing on 30 June and 31 December.
Guarding against common deficiencies in KYC and CDD is what separates a programme that survives examination from one that does not, and the board and senior management own that outcome.
Conclusion: Meeting UAE AML Law Requirements as a CMA-Regulated Forex Company
The AML obligations of a CMA-regulated forex company follow a clear regulatory framework. As a Financial Institution under the UAE AML/CFT regime, it is subject to Federal Decree-Law No. 10 of 2025, Cabinet Resolution No. 134 of 2025, the Capital Market Authority’s supervisory framework, targeted financial sanctions requirements, goAML reporting obligations, and the CMA Rulebook. The exposure gathers where a margin business is most vulnerable: quick onboarding, the origin of deposit and margin money, fast in-and-out payments, introducer arrangements, and surveillance for round-trip and matched trading. Firms that align their controls with this framework, regularly refresh their risk assessments, and maintain timely, accurate reporting and governance will be well positioned to demonstrate effective compliance with both the legal requirements and the supervisory expectations of the UAE AML/CFT/CPF regime.
FAQs on AML Regulations for Forex Companies in UAE
Which forex companies are subject to AML rules in the UAE?
Retail margin forex brokers, contracts for difference and derivatives providers, online trading platforms and their introducing brokers supervised by the Capital Market Authority outside the DIFC and ADGM are financial institutions under Federal Decree-Law No. 10 of 2025 and must run a full AML programme. Firms in the DIFC and ADGM follow the separate DFSA and FSRA regimes.
Is a forex company regulated by the Capital Market Authority or the Central Bank?
A firm that offers leveraged currency and derivative trading deals in securities products, so its licence and AML supervision both come from the Capital Market Authority under Federal Decree-Law No. 32 of 2025. A Central Bank-licensed exchange house is a different sector, concerned with physical currency exchange and remittance. Each falls under a different regulator, follows a different rulebook, and the two should not be conflated.
What source of funds checks are expected on client deposits and margin?
A forex company should establish and, where risk requires, corroborate the source of the funds a client deposits as margin, understand the customer’s source of wealth where appropriate, and treat unexplained, third-party or high-risk funding, and rapid round-trip deposits and withdrawals, as red flags warranting enhanced measures and, where appropriate, a suspicious transaction report through goAML.
How should a forex firm handle introducing brokers and affiliates?
A firm remains responsible for the clients an introducing broker or affiliate brings in. It should conduct due diligence on the introducer, understand the markets and client types it introduces, monitor for higher-risk business and bonus or rebate schemes that could disguise the movement of funds, and keep ultimate responsibility for customer due diligence with the firm, not the introducer, even where reliance is placed on a third party in accordance with the applicable legal requirements.
Do forex companies need a business-wide risk assessment?
Yes. The federal AML framework requires Financial Institutions to identify, assess and understand their money laundering, terrorist financing and proliferation financing risks using a business-wide risk assessment. CMA-regulated firms are expected to maintain and periodically update this assessment as part of their AML programme.
How should forex firms treat exposure to virtual assets and unlicensed providers?
Dealing in virtual assets and Virtual Asset Service Providers (VASPs) is subject to a separate regulatory framework alongside the securities rules covered here. Even so, a forex company should identify and manage any exposure to virtual assets or VASPs, apply the UAE Travel Rule where applicable, and treat dealings with unlicensed virtual asset providers or high-risk asset funding routes as higher-risk scenarios requiring enhanced due diligence.
Are older SCA AML notices still relevant now that the CMA has replaced the SCA?
Yes. Existing Securities and Commodities Authority notices, decisions and guidance continue to apply unless they have been repealed or are inconsistent with the new Capital Market legislation or subsequent regulations. Firms should keep applying instruments such as the SCA Board Chairman decision and the 2021 notices, while reading any mention of the earlier 2018 and 2019 regime through the lens of Federal Decree-Law No. 10 of 2025 and its Executive Regulations.
What penalties can the Capital Market Authority impose for AML failures?
Under Article 17 of Federal Decree-Law No. 10 of 2025 the Authority can issue a warning, impose administrative fines, ban a firm from the activity and revoke its licence. The Authority’s own examination observations put the fine range at AED 50,000 to AED 5,000,000 for each violation, alongside loss of licence in the most serious cases. Separately, a legal person that keeps an inaccurate beneficial owner register faces sanctions under Cabinet Resolution No. 132 of 2023, where a third breach lets the registrar suspend the licence and close the premises until the fine is paid and the violation remedied.
What AML returns must a CMA-regulated forex company file, and when?
Two periodic filings sit alongside event-driven goAML reporting. The annual AML/CFT and targeted financial sanctions risk assessment return runs across five tabs, covering customer risk, product and service risk, distribution-channel risk, signatories, and the controls and quality of mitigation, with figures stated in dirhams and country data given in standard names or codes. The semi-annual AML and CTF report covers the periods closing 30 June and 31 December, must be reviewed by the board, and is lodged with the Capital Market Authority together with the board’s remarks within two months of each period end.
Expert Tip: The Round-Trip Funding Pattern a Forex AML Programme Must Catch
For a forex company, the pattern that should never go unmonitored is money that comes in and goes straight back out. A client deposits margin, trades little or in matched positions, then withdraws to a different account or method. Build monitoring that flags rapid round-trip funding, mismatches between deposit and withdrawal methods, and trading that moves value rather than seeks profit, and tie it to source of funds evidence gathered at onboarding. Add real due diligence on the introducers who bring these clients in. This is where examinations and thematic reviews most often find the gaps in a margin trading business.
Is Your Forex Business Ready for a CMA Examination?
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About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is an ACAMS-certified AML consultant specialising in governance, risk, and compliance for regulated entities in the UAE. He brings over 28 years of experience, with 1,000+ hours of AML training and 200+ advisory engagements across DNFBPs, VASPs, and FIs. He supports businesses in aligning with AML/CFT requirements from the CBUAE, DFSA, MoET, MoJ, VARA, CMA, FSRA, and FATF. Known for translating complex regulations into audit-ready procedures, Pathik enables operational clarity and compliance readiness.
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