AML Compliance, UBO Declaration & goAML Registration
AML policies, risk assessment and goAML registration for businesses in the AML categories, and your beneficial-owner declaration.
AML compliance, beneficial owners and goAML
Three compliance files sit beside the tax file for many companies. AML compliance — written policies, a risk assessment and the controls behind them — for businesses in the categories the anti-money-laundering law designates. goAML, the reporting portal those businesses must register on. And the beneficial-owner (UBO) declaration, which almost every company keeps. We prepare them with you and file what has to be filed.
The Ministry of Economy and Tourism describes itself as “the competent Supervisory Authority” for designated non-financial businesses and professions “in the UAE mainland and Commercial Free Zones”, under “Federal Decree by Law No. (10) of 2025, Cabinet Resolution No. (134) of 2025, and any amendments thereto”. Its sectors are real estate agents and brokers, dealers in precious metals and stones, independent accountants and auditors, and trust and company service providers (Ministry of Economy and Tourism, AML/CFT/CPF supervision, read 14 November 2026). We are not a supervisor, an auditor or anyone’s compliance officer: we prepare the documents and filings, and your business owns them.
What we prepare and file
- AML policies and procedures written for your activity: customer due diligence, record keeping, reporting and sanctions screening
- A documented risk assessment of your business, as the law requires
- Compliance officer appointment support: the role described, the person's details prepared for the filings; the officer is someone your business appoints
- goAML registration for a business in a category that must register, and its details kept current
- The UBO declaration prepared from your MOA and shareholder register, and filed with the licensing authority
- UBO updates after a change of shareholders, managers or nominees
Get this quoted
Itemised in writing, government charges shown separately, before anything is filed.
Which one do you need?
Who this applies to
- Businesses in the Ministry's supervised sectors: real estate agents and brokers, dealers in precious metals and stones, independent accountants and auditors, and trust and company service providers (Ministry of Economy and Tourism)
- Mainland and free zone companies filing or updating their beneficial-owner details
- Companies whose ownership changed after a share transfer
Whether your activity falls in an AML category is confirmed with you at quotation.
What we need from you
- Trade licence and MOA
- Shareholder register and the chain of ownership up to the individuals
- Passports and Emirates IDs of the beneficial owners and managers
- For AML work: a description of your customers, products, payment methods and countries you deal with
- For goAML: the licence and the appointed compliance officer's details and contact information
We confirm the final list with you at quotation.
How the work runs
- Your activity read with you, and whether it falls in an AML category.
- A written quote.
- Risk assessment and policies drafted for your business, or the UBO declaration prepared.
- Your approval: senior management approves the policies, as the law asks.
- Filing: goAML registration, or the UBO declaration with the licensing authority.
- The file kept for the next change of officer, licence or owner.
What the authorities publish
Federal Decree-Law No. 10 of 2025 (UAE Legislation, issued 30 September 2025), Article 19(1):
- (a) "Identify, understand, manage, assess, document, and continuously update the risks of the Crime"
- (d) "Establish internal policies, controls, and procedures, approved by senior management"
- the detail, including the compliance officer rules, is in its executive regulations, Cabinet Resolution No. 134 of 2025
goAML (Ministry of Economy and Tourism, read 14 November 2026): "Registration of Designated Non-Financial Companies on goAML Portal is Mandatory"; "All Designated Non-Financial Businesses and Professions (DNFBPs) were required to register on the goAML portal."
UBO (Ministry of Economy, 21 December 2023), under Cabinet Decision No. 109 of 2023: a nominee manager or board member informs the company of the role and provides the required data, and reports a change, within 15 days.
Fees: Quote on request. Our service fee is quoted in writing after a short review of your file, and any authority charge is listed separately in your quote.
AML policies and risk assessment
The law starts from risk: the business identifies and documents how it could be misused, then writes the policies and controls that answer those risks, and senior management approves them. We draft both from how your business actually works — who your customers are, how they pay, where they are — so the documents describe your business, not a template.
goAML registration
goAML belongs to the anti-money-laundering framework, not to tax. A business in one of the designated categories registers its organisation and a compliance officer on the portal; we prepare the registration and keep its details current when the licence or the officer changes.
UBO declaration
The declaration follows the ownership chain up from the shareholders on the MOA to the individuals at the top of it. We draw that chain with you from the documents, so the record filed with the licensing authority matches the licence and the IDs.
Not published officially
- A fixed template for AML policies. The law sets what they must cover; the content depends on your business.
- A company deadline for submitting UBO data in the Ministry's article quoted here. It gives the nominee periods, not a filing date for the company.
- Any register that lists us. We are not a supervisor, an AML auditor or a compliance officer provider, and do not say so.
AML, UBO and goAML questions
Who supervises AML compliance for businesses like mine?
For its sectors, the Ministry of Economy and Tourism, which calls itself "the competent Supervisory Authority" for those DNFBPs "in the UAE mainland and Commercial Free Zones" (MoET). We are not a supervisor.
Which businesses are in those sectors?
Real estate agents and brokers, dealers in precious metals and stones, independent accountants and auditors, and trust and company service providers (MoET). Whether your activity is one is confirmed at quotation.
What does the law ask a business to do?
Among other things, to "Identify, understand, manage, assess, document, and continuously update the risks of the Crime" and to "Establish internal policies, controls, and procedures, approved by senior management" (Federal Decree-Law No. 10 of 2025, Article 19(1)).
Do you act as our compliance officer?
No. The compliance officer is someone your business appoints; we help describe the role and prepare the officer's details for the filings.
Who must register on goAML?
The Ministry states that "All Designated Non-Financial Businesses and Professions (DNFBPs) were required to register on the goAML portal" (MoET).
What is goAML?
The portal the Financial Intelligence Unit uses to receive suspicious transaction and activity reports (MoET).
What is a UBO declaration?
A record of the individuals who ultimately own or control the company, kept under "Cabinet Decision No. 109 of 2023 on the organization of the real beneficiary procedures" (Ministry of Economy).
Does UBO apply to free zone companies?
The Ministry describes the decision as covering "all private sector enterprises within the country, including those in commercial free zones" (Ministry of Economy, 21 December 2023).
Do you audit our AML compliance?
No. We prepare the policies, the risk assessment and the filings; inspections are the supervisor's.
Is this a tax filing?
No. AML and goAML belong to the anti-money-laundering framework and UBO to the licensing authority; we handle them beside the tax file because the same documents feed all three.
Every rule, deadline and threshold above names the authority that published it and the date shown on its page when we read it on 14 November 2026: the Federal Tax Authority (tax.gov.ae), the Ministry of Finance (mof.gov.ae) and the federal portal u.ae. Tax rules, fees and processing times are set by the authorities and can change without notice; confirm with the FTA before you rely on them. AL HUDHUD prepares and files on your instructions; your position is confirmed with you at quotation, and every decision rests with the Federal Tax Authority.
Last updated: November 2026.
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