How Real Estate, Accounting, and Jewellery Firms Can Stay 100% MoEc-Ready Under the New AML Rulebook
The Ministry of Economy (MoEc) has tightened the AML/CFT inspection framework for all Designated Non-Financial Businesses and Professions (DNFBPs).
Real estate brokers, jewellery dealers, auditors, accountants, and company service providers must now prove — not just claim — that they are compliant.
The 2025 Revised Guidelines (V2) emphasize:
- Verified Business Risk Assessments (BRA)
- Documented Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
- Sanctions and PEP screening using UAE and UN lists
- Evidence of monitoring and record-keeping, not just templates
At Fastlane, we’ve been working with DNFBPs daily — and here’s what real-world compliance looks like under the new rules.
1. Offshore or Complex Buyers — CDD Is No Longer a Form
A BVI company wants to buy a Dubai property via an offshore bank.
Old approach: Collect incorporation docs and a declaration form.
2025 approach: Trace and verify the ultimate beneficial owner (UBO) using authenticated, apostilled registry extracts.
You must:
- Identify who controls the company (not just who owns shares).
- Verify both the source of funds (SoF) and source of wealth (SoW).
- Run sanctions & PEP screening before any payment is received.
- Obtain MLRO approval for onboarding.
💡 Inspectors now ask for proof of authentication — not declarations.
Your BRA must evolve as your business does.
Every 12 months, use internal data to re-evaluate:
% of clients from high-risk countries
% of PEPs or offshore entities
Total STRs filed
Transaction growth or new services
If your exposure changes, your risk scores and controls must too.
Document the update and get it signed by your Compliance Officer and Managing Partner.
A UAE official purchases property via a family company.
Even if the PEP is local, the risk classification is still high.
DNFBPs must:
- Screen both the PEP and related parties.
- Obtain SoF (salary slips, bank statements) and SoW (asset statement).
- Record senior management approval before completing the transaction.
💡 Domestic PEPs are no longer “trusted clients” — they’re “high-risk clients under EDD.”
An agent offers AED 7 million in cash “from a private buyer.”
Your answer should always be: “Refuse and Report.”
Under Federal Decree-Law 20 of 2018, you must:
- Decline the transaction without verified KYC.
- Document and escalate to your MLRO.
- File a Suspicious Transaction Report (STR) via goAML within 24 hours.
💡 Convenience doesn’t excuse compliance — STRs show you’re protecting the system, not stopping business.
If a third party pays for property, gold, or professional fees on behalf of another:
- Verify their relationship to the buyer.
- Obtain UBO details and payment evidence.
- Apply EDD and MLRO approval.
- File an STR if the link between payer and buyer is weak or undocumented.
💡 “Who paid and why?” is now the MoEc’s favorite inspection question.
- If one account funds multiple buyers or family members:
- - Verify the economic relationship between all parties.
- - Trace all payments to the same account.
- - Apply EDD on the actual funder, not just the nominal buyers.
💡 It’s not who signed — it’s who paid. Structuring is the new layering.
A non-resident wants to buy gold and pay in Bitcoin.
Under the 2025 MoEc guidelines:
- Only licensed VASPs can handle crypto payments.
- Jewellery and real estate businesses must not accept direct wallet-to-wallet transfers.
- Conduct EDD + blockchain screening if offered.
- File an STR if funds come from an unlicensed or unverified wallet.
💡 Crypto is treated like cash — but with extra red flags.
Jewellery shops often overlook repeat small transactions under AED 55,000.
But if the same customer buys AED 10,000 worth of gold repeatedly — that’s structuring.
You must:
- Aggregate purchases by customer name or ID.
- Apply full CDD once cumulative value crosses the threshold.
- File an STR if the customer refuses KYC.
💡 Multiple small transactions = one large red flag.
Using AML Plus or similar tools isn’t enough.
You must prove:
- Screening covers both UAE and UN lists.
- Results are reviewed and logged manually.
- Hits are cleared with evidence (date, officer initials, list version).
💡 MoEc’s 2025 inspections now ask: “Show me the last time you checked your active clients against the updated Cabinet list.”
Fastlane helps DNFBPs stay inspection-ready with a complete AML toolkit, including:
✅ Business Risk Assessment (BRA) tailored to your sector
✅ Customer Risk Matrix & KYC file templates
✅ PEP, Sanctions, and Adverse Media Screening logs
✅ AML/CFT Policy & MLRO Handbook (MoEc-aligned)
✅ Monthly Compliance Reviews & STR Support
💰 From AED 499/month — 100% MoEc-compliant setup
📅 Get your free compliance audit within 7 days.
