The Cabinet Resolution No. (109) of 2023 on Regulating the Real Beneficiary Procedures requires Regulated Entities to establish a framework for identifying and verifying the Ultimate Beneficial Owners (UBOS) of legal persons.

DNFBPs, therefore, have a two-fold responsibility, one being submitting their own accurate Real Beneficiary Register and having in place an AML/CFT Compliance Program that helps identify and verify the UBOs of every client the DNFBP onboards as a core component of their CDD exercise.

Failure in either of these two responsibilities results in a regulatory breach of the UBO Law, which invites administrative fines and penalties.

This is why we have developed and come up with the Annual UAE UBO Checklist: Real Beneficiary Verification for AML/CFT Compliance. This checklist works as a practical guide with actionable pointers providing a structured methodology for DNFBPs to manage and organise their internal AML/CFT Compliance Framework and align their CDD processes to ensure compliance. The checklist contains:

• Two-Part Annual Checklist: Covering both the DNFBPs’ own reporting requirements and external client identification and verification duties.
• A ready-to-use RACI Matrix to delegate tasks across the organisation to ensure well-coordinated task allocation and assignment of accountability around the UBO review process.
• Key best practices around ensuring compliance with UBO Law and the Latest Guidelines for DNFBPs issued in 2025 to avoid common compliance pitfalls.

Do not wait for the regulatory inspection to find flaws in your UBO Compliance Framework. Demonstrate proactive Real Beneficiary compliance by downloading and arming yourself with the actionable pointers mentioned in the Checklist.

Our Checklist for Identifying Shell Company Misuse for Ensuring Robust AML/CFT Compliance is aimed at simplifying the responsibility of FIs, DNFBPs and VASPs to identify and mitigate the ML/FT and PF risks emanating from the misuse of Shell Companies by illicit actors.

This checklist gives clear and easy methods to identify Shell Company misuse. It acts as a practical framework for Regulated Entities for effective and efficient Shell Company misuse identification.

The checklist helps in identifying Shell Company Red Flags in four catagories such as:

• Entity and Structural Risk
  • Complex Ownership
  • Nominee Appointments
  • Shared Address
  • Bearer Shares
  • Aged ‘shelf’ Company
• Jurisdictional and Operational Risk
  • High Risk Jurisdiction
  • No Physical presence
  • Generic Business Purpose
  • Anonymity/ Face to Face
• Transactional Risk
  • Lack of Economic Rationale
  • Inconsistent Activity
  • Rapid Fund Movement
  • Unrelated Third Parties
• Governance and Documentation Risk
  • UBO Evasion
  • Incomplete Documentation
  • Adverse Media
  • Refusal/ Suspicion

The checklist also comes with a RACI chart, which helps with shell company risk identification and management, enabling seamless coordination and task allocation when it comes to defining roles and responsibilities across the organisation to personnel such as Frontline Staff, AML Compliance Officer, Compliance Team, and Senior Management in the context of identifying Shell companies misuse, escalating suspicious cases and reporting the same to the UAE FIU through the goAML portal.

Download this checklist to fortify the fight against misuse of legal structures such as Shell Companies.

Any DNFBP’s AML/CFT Compliance framework’s robustness hinges entirely upon their system readiness and regulatory reporting precision. AML/CFT Compliance landscape in UAE requires DNFBPs to have flawless internal systems and controls to meet regulatory reporting requirements, including Targeted Financial Sanctions (TFS) compliance requirements through the goAML portal.

This is why every DNFBP must conduct a comprehensive Annual goAML System Readiness and & TFS Compliance audit. DNFBPs must have verifiable controls as mandated by the FIU and the Executive Office for Control and Non-Proliferation (EOCN).

The Annual goAML System Readiness & TFS Compliance Checklist for DNFBPs can be used as an essential governance tool for identifying gaps or issues in a DNFBP’s goAML reporting and TFS compliance framework, as it helps to identify underlying gaps and blind-spots in a business’s goAML reporting procedures and TFS compliance measures, enabling the DNFBP to take corrective and timely action to remedy issues identified to ensure continuous AML/CFT and TFS compliance with sound goAML reporting procedures in place.

With the Financial Action Task Force (FATF) updating its “Grey List” or “Jurisdictions under increased monitoring” list thrice a year, it becomes vital for Regulated Entities in UAE to be prepared with the necessary actionable steps, processes, and workflows that can be triggered immediately upon revision, addition, and deletion to the FATF Grey List.  

Each time FATF issues a Grey List update, Regulated Entities are required to recalibrate their: 

• Enterprise-Wide Risk Assessment  
• Customer Risk Assessment Models 
• Enhanced Due Diligence triggers and procedures 
• Recalibration of AML/CFT Software and tools. 

Our Checklist + RACI Matrix helps Regulated Entities to be prepared and armed with necessary measures as and when FATF issues new Grey List, with additions and deletions of countries, directly impacting the geographic risk component, that need to be modified and incorporated into the Regulated Entity’s AML/CFT Policies, Procedures, and Controls Documentation. 

Do not wait for the regulator’s next inspection to find a gap pertaining to FATF Grey List adherence in your AML/CFT Framework. Demonstrate proactive AML/CFT compliance by downloading and arming yourself with the Checklist to Identify AML/CFT Programme Alignment with FATF Grey List Updates. 

Corporate vehicles are widely used in today’s economy for legitimate business activity, but their complexity and cross-border activities’ lack of transparency can be exploited to hide ultimate owners and enable illicit funds transfer that finances terrorism and other crimes. For Regulated Entities, this poses a serious AML/CFT challenge while businesses benefit from a legitimate corporate structure. They must stay vigilant to detect and mitigate the misuse of these vehicles for Terrorism Financing.  

Here is one-click-away, easily downloadable “Checklist to Identify of Misuse of Corporate Structures to Strengthen AML/CFT Compliance” + RACI Chart, designed to help you identify suspicious corporate structures, trace obscure ownership, detect anomalies, financial flows, and escalate cases efficiently. 

So, if you are part of the customer onboarding team, KYC analyst, a screening analyst, an AML compliance, a Transaction Monitoring Analyst, a Senior Manager, or a Compliance enthusiast, you must be equipped with the right tools to identify red flags and take action.  

• Identifying the effectiveness of control measures surrounding documents, customers, transactions and third-party or intermediaries to detect any red flags indicating concealment of funds. 

• Identifying whether regulatory reporting and AML training components are designed well enough to mitigate loopholes in corporate structure. 

• Recognising the concealment of funds through nominees, incomplete data or refusal to provide adequate ownership information. 

• Identifying process efficiency for red flag indication around transactions, financial inconsistency, which might be associated with ML, TF and PF activities. 

• Designing workflow, role clarity, task allocation and task escalation for managing cases with fund management abuse. 

• Ensure timely filing of Suspicious Activity Report (SAR) and Suspicious Transaction Report (STR) with the UAE FIU through the goAML portal.  

Download this “Checklist to Identify Misuse of Corporate Structures to Strengthen AML/CFT Compliance” today and align your business with AML/CFT regulations, while addressing real-world risks associated with the misuse of corporate vehicles. 

It is necessary for Regulated Entities to analyse the movement of funds through Regulated Entities. Regulated Entity’s personnel such as a member of the customer onboarding team appointed as frontline staff, MLRO or transaction monitoring analysts, needs to assess, mitigate or report the risks related to movement and obscuring of funds through Regulated Entities. 

Here is a ‘one-click away’ downloadable Checklist for Recognising Disguising of Funds to Ensure Robust AML/CFT Compliance + RACI matrix to ease your compliance work. This checklist includes: 

• Identifying obscure fund movements across DNFBPs, VASPs, and FIs that may indicate ML/TF. 

• Assessing control measures for document verification, customer profiling, and cross-border transactions to detect unusual patterns and layering. 

• Implementing a RACI matrix to assign roles and responsibilities and escalation when suspicious activities arise. 

• Strengthening regulatory compliance by aligning with FATF guidelines and domestic AML/CFT expectations. 

Download this checklist for Recognising Disguising of Funds to Ensure robust AML/CFT compliance + RACI matrix, whether you are in Dubai or Abu Dhabi, to align your business with robust AML/CFT compliance. 

Real Estate brokers and professionals in UAE need to focus their attention and resources on closing high-value property deals such as securing commercial lease, dealing with luxury villas, facilitating off-plan purchases, etc.

However, the real estate sector is prone to being misused by money launderers and criminals to further their illegal motives. That adequately emphasises and calls for conducting an Annual Review of a real estate business’s AML/CFT Program not only to ensure fulfilment of compliance obligations but to diagnose issues in the existing framework by conducting health-check of business’s ML, FT and PF risk mitigation measures. 

Here’s a checklist for all real estate DNFBPs, including brokers, agents, and other professionals dealing or facilitating with real estate transactions such as lawyers, notaries, and accountants. This Annual AML Review Checklist for Real Estate Businesses  is a comprehensive guide that provides clear roadmap to assess the efficacy of mitigation measures such as: 

• Customer Due Diligence and identification and verification of Ultimate Beneficial Owners (UBOs) 
• Sanctions Screening for TFS compliance 
• Timely filing of regulatory reports 
• A clear RACI Matric to delegate compliance task responsibilities across the organisation. 

Download this Annual AML Review Checklist for Real Estate Businesses to align your real-estate business’s AML compliance with UAE’s legal requirements and protect your business from financial crimes. 

Regulated Entities must stay cautious of insiders, i.e., employees or executives who can manipulate AML systems, override alerts, or suppress reporting to enable Money laundering (ML) and terrorism Financing(TF) to aid their criminal aids.

Here is the downloadable and no-questions asked Insider Threat in AML Compliance detection Checklist for AML/CFT + RACI matrix

This Checklist is specifically designed to simplify AML Compliance teams’ responsibilities, to detect insider complicity or insider involvement through measures such as:

• Accessing the effectiveness of control measures surrounding employees’ access, authorisations, reporting channels, and whistleblower protections to identify or detect any red flags indicating insider abuse or collusion.
• Identifying whether regulatory reporting and AML training components are strong enough to mitigate insider risks such as SAR suppression, alert overrider, or tipping-off.
• Identifying process efficiency for red flag detection related to unusual staff behaviours such as bypassing procedures, privilege escalation, and conflicts of interest. Which may indicate insider involvement in ML, TF, or PF activities.
• Structuring the operational roles, task allocation, and task escalation for managing insider-threat cases, ensuring segregation of duties and independent internal SAR reviews.
• Ensuring timely filing of SAR/STRs with the UAE FIU through goAML portal when red flags are detected and reported, without obstruction or delay.

Download this checklist for Insider Threat in AML/CFT, whether you are in Dubai or Abu Dhabi, as UAE regulations require Financial Institutions & DNFBPs to strengthen governance, protect systems from misuse by insiders and align the business’s AML/CFT measures with realistic insider threat scenarios and red flag indicators.

This checklist will help you assess your preparedness, mitigate insider risks, and reinforce your AML Framework.

Regulated Entities need to identify weaknesses in their Anti Money Laundering (AML), CFT and TFS processes, which involve screening of individuals against sanctions lists. You might be checking the individual’s name against the UAE Local Terrorist List, the UNSC Consolidated List and other relevant lists, but it is necessary to ensure that no deficiencies arise due to outdated technology, ineffective screening process, data quality issues or others.

Here’s an easily downloadable, accessible and no-questions-asked “Checklist for Identification of Sanction Screening Gaps to Ensure Robust AML/CFT, TFS Compliance” + RACI Matrix, including a pocket-sized “RegTech Dictionary”, simplifying the compliance and technology aspects of Sanctions Screening Software.

If you are a part of the customer onboarding team, a Screening Analyst, IT/System Admin, a Compliance Officer, a Senior Board Member or an AML Enthusiast, this checklist is designed to ease your and your team’s roles and responsibilities, such as:

• Assessing the effectiveness of control measures surrounding documents, customers, transactions, and counterparties to identify or detect any red flags indicating sanctions screening lapse
• Identifying whether the regulatory reporting and AML training components are designed well enough to mitigate sanctions screening gaps
• Identifying process efficiency for red-flag detection around name screening negligence, which might be indicators of underlying ML, TF, or PF activities
• Designing workflow, role clarity, task allocation, and task escalation for managing cases with screening compliance failures
• Ensuring timely filing of CNMR, PNMR and other relevant reports with the UAE FIU through the goAML portal when red flags are detected.

Download this “Checklist for Identification of Sanction Screening Gaps to Ensure Robust AML/CFT, TFS Compliance” whether you’re in ADGM, Dubai Silicon Oasis (DSO), DMCC or RAKEZ, to align your business with realistic sanctions screening and assess your business’s readiness to mitigate sanctions screening lapse to combat ML, FT and PF risks.

Information privacy is not only necessary to carefully handle customers’ data according to prevailing AML/CFT regulations and the data privacy laws, but also to reduce potential risks to customers’ personal information. Customer data is prone to risks of data breaches and mishandling, which may lead to severe financial loss, reputational damage and even legal penalties to Regulated Entities.

Here is the “one-click-away”, easily downloadable, with a no-questions-asked AML Data Governance Checklist: Minimise Information Privacy Abuse, Maximise Compliance + RACI Matrix.

If you are a part of the customer onboarding team, a KYC Analyst, an AML Compliance officer, a Senior Board Member, a Transaction Monitoring Analyst, someone who’s an AML enthusiast keen on data privacy abuse risk, or anyone responsible for AML governance and information privacy, this checklist is designed to provide you with insights into information privacy abuse risk and simplify your below roles and responsibilities:

• Assessing the effectiveness of control measures surrounding documents, customers, transactions, and counterparties to identify and detect any red flags indicating data breaches and data misuse.
• Identifying whether the regulatory reporting and AML training components are designed well enough to mitigate data privacy abuse risk
• Identifying process efficiency for red-flag detection around misuse or breach of customer data, which might be indicators of underlying ML, FT or PF activities
• Designing workflow, role clarity, task allocation, and task escalation for managing cases with data privacy abuse
• Ensuring timely filing of CNMR, PNMR, SAR or STRs with UAE FIU through goAML portal when red flags are detected.

Download this “AML Data Governance Checklist: Minimise Information Privacy Abuse, Maximise Compliance” + RACI Matrix, whether you have business operations in Dubai, Sharjah, Abu Dhabi or other parts of the UAE, to align your Regulated Entity with data privacy laws and abide by AML rules and regulations.