The goAML Web Submission Guide, issued by the UAE Financial Intelligence Unit in July 2022, sets out how to submit a report to the FIU through the goAML platform. It is addressed to the designated Compliance Officer or Money Laundering Reporting Officer of a registered reporting entity, or the deputy where the lead officer is unavailable. It gives an overview of report types, including the Suspicious Transaction Report and the Suspicious Activity Report, the latter covering suspected activity or an attempted, non-executed transaction, alongside the Additional Information File, Request for Information and High Risk Country reports. For dealers, managers, advisers and custodians, it standardises how suspicions are reported promptly.

CMA Notice 1/2022, dated 19 May 2022, directs all licensed financial institutions to implement Targeted Financial Sanctions under UN Security Council Resolutions 1718 (2006) and 2231 (2015), pursuant to Cabinet Resolution No. 74 of 2020. Broker-dealers, asset managers and custodians must screen every party to a financial transaction, apply enhanced due diligence to dealings linked to relevant countries, and verify cross-border flows suspected of unauthorised trade in dual-use goods. Confirmed matches require a Funds Freeze Report through goAML within five business days, potential matches a Partial Name Match Report, and suspicious activity an STR to the Financial Intelligence Unit. Firms should consult Executive Office guidance and prevent sanctions evasion.

The Capital Market Authority AML/CFT Guidance for the Capital Market Sector, dated September 2021, supplements the main Financial Institutions Guidelines and sets out the Securities and Commodities Authority’s expectations for firms it licenses. It applies to boards, management and employees of institutions carrying out securities activities in the UAE, read with those wider guidelines. Part 1 surveys sector typologies, including trade-based money laundering through mis-invoicing and misrepresentation of price, quantity or quality, and cash-based laundering, with red-flag indicators. Parts 2 and 3 explain the risk-based approach, business-wide risk assessment and the customer, product, delivery-channel and geographical risk factors that brokers, asset managers and advisers must identify, assess and mitigate.

The SCA Board Chairman’s Decision No. 21/Chairman of 2019, issued on 8 May 2019 and active from 7 May 2019, applied anti-money laundering, counter-terrorism financing and illegal-organisations financing procedures to the capital market. Signed by Sultan bin Saeed Al Mansouri, it required every financial entity licensed or approved by the Securities and Commodities Authority, and its stakeholders, to comply with Federal Decree-Law No. 10 of 2025, its executive regulation under Cabinet Resolution No. 134 of 2025, and the Authority’s instructions, guidelines and circulars. It empowered the Authority to supervise and inspect firms without notice, demand information, and impose administrative sanctions on brokers, fund managers and other market participants.

Issued in March 2022, this joint guidance from the UAE Supervisory Authorities, including the Central Bank, the Securities and Commodities Authority and the Virtual Assets Regulatory Authority, aligns with FATF’s risk-based approach and warns the public and regulated firms about unlicensed virtual asset providers. It urges confining virtual asset dealings to licensed entities and reminds exchange houses of their AML obligations. Expectations include vigilance to fraud, factoring emerging risks into assessments, adequate due diligence, spotting customers who seek unlicensed providers, and reporting suspicions. Red flags include no licence, no physical presence, unrealistic promises or Ponzi schemes, poor websites and pressure to invest quickly, helping counter staff intercept suspect remittances.

Federal Decree-Law No. 6 of 2025 on the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business, issued on 8 September 2025, is not the AML law, but it matters as regulatory background for a CBUAE-licensed exchange house. It governs the Central Bank’s role and the regulation of licensed financial institutions and financial activities, which is the regime under which the firm holds its licence and answers to its supervisor. An exchange house should read it alongside the AML framework when assessing its licensing, conduct and supervisory position.

Suspicious remittances are the daily bread of an exchange house, and this CBUAE guidance of 3 August 2022 explains how to identify, investigate and report them. It sets out the legal basis for filing, the protection for those who disclose, the meaning of a suspicious transaction, and the consequences of staying silent on structured cash or unusual transfer patterns. The document maps the three lines of defence, the role of the compliance officer or MLRO, transaction monitoring methods from manual to intelligence-led, and how to draft and submit a report. It also covers immediate-attention activity, confidentiality and the strict prohibition on tipping off remittance customers.

No customer type sits closer to an exchange house than the cash-intensive business, and this CBUAE guidance of September 2021 addresses precisely the risks that arise when clients handle large volumes of notes at the counter. Issued under article 44.11 of Cabinet Decision No. 10 of 2019 (now repealed and replaced by Cabinet Decision No. 134 of 2025, under which supervisory guidance is issued pursuant to Article 49.4), it explains why cash is so vulnerable to abuse, the risks of bearer negotiable instruments and prepaid cards, and specific concerns including cross-border cash movement, couriers and currency exchange. On mitigation, it sets a risk-based approach built on enterprise and customer risk assessment, enhanced due diligence, beneficial owner identification, ongoing and transaction monitoring, suspicious transaction reporting, governance and training for high cash flows.