Insurance brokers in the UAE are fully in scope of the country's anti-money laundering regime, and their supervisor since the Insurance Authority's merger into the Central Bank of the UAE is the Central Bank itself. Under Federal Decree-Law No. 10 of 2025 (the UAE's current AML law) and the Central Bank's AML/CFT supervision of the insurance sector, a broker must run a risk-based programme: customer due diligence, beneficial-owner identification, sanctions screening, suspicious transaction reporting through goAML, record keeping and staff training. The Central Bank's July 2025 thematic review found real gaps at insurance companies, brokers and agents — and warned that repeat findings lead to enforcement. This guide sets out what a UAE insurance broker must have in place in 2026 and cites the source for each requirement.
Who regulates insurance brokers for AML in the UAE?
The Central Bank of the UAE assumed supervisory and regulatory responsibility for the insurance sector under Decretal Federal Law No. 25 of 2020, which merged the Insurance Authority into the Central Bank (CBUAE — Insurance). That includes AML/CFT supervision: the CBUAE's AML Department runs risk-based supervision over insurance companies, brokers and agents, and publishes its expectations and review findings.
The AML obligations themselves now sit under Federal Decree-Law No. 10 of 2025 Regarding Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, which carries forward and strengthens the framework of the earlier Federal Decree-Law No. 20 of 2018. The National Strategy for AML/CFT/CPF (2024–2027) keeps the focus on a risk-based approach.
What the Central Bank found in the insurance sector
The CBUAE's AML/CFT/CPF Thematic Review of the Insurance Sector (July 2025) assessed insurance companies, brokers and agents and required operators to remediate its findings by 1 September 2025. Its core message: repeat findings lead to interventions, up to formal supervisory powers and enforcement action. For brokers, the review is effectively a public checklist of what supervisors look for.
A broker's AML obligations in 2026
| Obligation | What it means for an insurance broker | Cadence | Source |
|---|---|---|---|
| Risk assessment | Document money-laundering and terrorism-financing risks by product, channel and customer type — life and investment-linked products carry higher risk | Annually and on change | Federal Decree-Law No. 10 of 2025 |
| Customer due diligence (CDD) | Identify and verify customers before arranging cover; understand the purpose of the policy | At onboarding, and on trigger events | Federal Decree-Law No. 10 of 2025 |
| Beneficial owner | Identify the natural person who ultimately owns or controls a corporate customer | At onboarding | Federal Decree-Law No. 10 of 2025 |
| Enhanced due diligence (EDD) | Apply to higher-risk customers and products — complex structures, high-value policies, unusual premium flows | Case by case | Federal Decree-Law No. 10 of 2025 |
| Sanctions and screening | Screen customers and related parties against UN and local sanctions lists | At onboarding and on list updates | Federal Decree-Law No. 10 of 2025 |
| Suspicious transaction reporting | File STRs/SARs promptly via goAML; tipping-off is prohibited | As arising | Federal Decree-Law No. 10 of 2025 |
| Record keeping | Keep CDD records and transaction documents for the statutory minimum of 5 years | Continuous | Federal Decree-Law No. 10 of 2025 |
| AML programme and training | Appoint a compliance officer, approve policies, train staff; the board owns the framework | Ongoing, with periodic reviews | Federal Decree-Law No. 10 of 2025 |
Broker-specific risk points
- You act for insurers but own your own obligations — a broker's AML duties are independent of the insurer's; relying on the insurer's checks is only acceptable within the reliance conditions of the law, and responsibility stays with the relying party.
- Premium flows and refunds — policies bought with third-party funds, early surrenders and refunds to different accounts are classic layering patterns; treat them as red flags.
- Intermediaries and sub-agents — chains of agents weaken visibility of the end customer; document who performs CDD in the chain.
- New products and distribution channels — any new product or channel needs a documented risk assessment before launch.
A 90-day AML compliance checklist for a UAE broker
| Step | Output |
|---|---|
| 1. Enterprise-wide risk assessment | Documented risk matrix by product, customer and channel |
| 2. Policy and procedure refresh | Board-approved AML policy aligned to Federal Decree-Law No. 10 of 2025 |
| 3. CDD and beneficial-owner files | Complete, verified files for all active clients |
| 4. Screening set-up | Sanctions and PEP screening at onboarding and on list updates |
| 5. goAML registration check | Active goAML access for the reporting pathway |
| 6. Training | Documented AML training for all staff, refreshed annually |
| 7. Independent review | Periodic internal or external review of the programme |
Frequently asked questions
Do insurance brokers in the UAE have AML obligations, or only insurers?
Brokers have their own AML obligations under Federal Decree-Law No. 10 of 2025 and are directly supervised by the Central Bank of the UAE, which took over the insurance sector's supervision when the Insurance Authority was merged into it under Decretal Federal Law No. 25 of 2020.
Where do suspicious transaction reports go?
Suspicious transactions are reported through the goAML portal under the CBUAE's supervision. Reporting is confidential, and tipping off a customer that a report was filed is an offence.
What happens if a broker fails an AML inspection?
The CBUAE's July 2025 thematic review states that repeated findings can lead to interventions including formal exercise of supervisory powers or enforcement action. Gaps identified in a review should be remediated on a documented timeline.
Finanshels builds AML programmes for UAE regulated businesses — talk to our AML team before your next supervisory review.
