A free zone licence changes who supervises a company, not what the company owes under UAE anti-money-laundering law: any free zone entity that falls into a designated non-financial business and profession (DNFBP) category carries the same duties as its mainland equivalent under Federal Decree-Law No. 10 of 2025 — documented risk assessment, customer due diligence, a compliance officer, goAML registration and suspicious-transaction reporting to the UAE Financial Intelligence Unit.
Which free zone companies are DNFBPs
- Auditors and external accountants.
- Corporate service providers — company formation, registered office, nominee services.
- Dealers in precious metals and stones that trade at or above the cash thresholds in the implementing rules.
- Real estate brokers and agents.
A marketing agency, trading company or restaurant in a free zone is generally not a DNFBP; an accounting firm or a company-formation provider is, on day one.
The law and your supervisor
Federal Decree-Law No. 10 of 2025 is the current AML framework, replacing Federal Decree-Law No. 7 of 2018. Some free zone authorities are designated supervisors for DNFBPs licensed in their jurisdiction; others leave supervision to federal ministries. Confirm in writing who supervises your entity before building the compliance file — the obligations are federal, but the reporting line is not always the same.
The five duties
- Enterprise-wide risk assessment — documented, proportionate to the business, and refreshed when the risk profile changes.
- Customer due diligence — identify and verify the customer and the beneficial owner; apply enhanced due diligence to higher-risk relationships, including politically exposed persons.
- A compliance officer (MLRO) with the authority and independence to escalate.
- Registration on goAML and filing of suspicious transaction and activity reports with the UAE FIU through the goAML portal.
- Records kept at least five years from the end of the business relationship or transaction.
| Duty | What it means in practice | Where it lives |
|---|---|---|
| Risk assessment | Documented, entity-wide, refreshed | Compliance manual |
| CDD / EDD | Identity, beneficial owner, purpose of relationship | Onboarding file |
| goAML registration | Register the entity and its users | goaml.ae |
| STR / SAR reporting | File through goAML per FIU rules | goAML portal |
| Records | Five years minimum | Secure archive |
Penalties
Administrative fines for legal persons scale up to AED 5,000,000 for serious breaches, with criminal liability available under the decree-law; free zone authorities can add licence sanctions of their own. Under-documentation — a missing risk assessment, a silent goAML registration, unverified beneficial owners — is what triggers them.
Decision checklist
- Confirm whether your activity puts you in a DNFBP category.
- Identify your supervisory authority in writing.
- Register on goAML if not already registered.
- Appoint the compliance officer and document the appointment.
- Bring the risk assessment and CDD files up to the compliance file.
FAQ
Does a free zone company have to register on goAML? If it is a DNFBP — auditors, accountants, corporate service providers, precious metals and stones dealers, real estate brokers — yes; registration and reporting run through goAML regardless of where the licence sits.
Who supervises AML inside a free zone? It depends on the free zone: some authorities are designated supervisors, others fall under federal ministries — confirm yours before building the compliance file.
How long must AML records be kept? At least five years from the end of the business relationship or the transaction.
Finanshels provides AML compliance services guidance alongside bookkeeping services — see also AML compliance for accounting and bookkeeping firms, AML compliance for corporate service providers and AML compliance for auditors.
Reviewed by Krishna Subash Nair, Anti-Money Laundering Consultant at Finanshels. Last reviewed 21 September 2026. Rules reflect Federal Decree-Law No. 10 of 2025 as of that date; confirm your specific facts before acting.
