KYC and AML Readiness for UAE Licensed Firms: How to Prepare for 2025 EMLO Requirements

by Aug 8, 2025

With the UAE’s Executive Office for AML/CFT ramping up inspections in 2025, licensed entities must demonstrate stronger KYC and AML controls. This article explores how regulated firms can implement privacy-first onboarding, continuous screening, and full audit-ability using iComply.

The United Arab Emirates (UAE) has made major strides in aligning with global anti-money laundering (AML) and counter-terrorism financing (CTF) frameworks. Since being grey-listed by the FATF in 2022 and then removed in 2024, the UAE has doubled down on enforcement – particularly through the Executive Office for AML/CTF (EMLO).

In 2025, firms regulated by the UAE Central Bank, Securities and Commodities Authority (SCA), Dubai Financial Services Authority (DFSA), and Abu Dhabi Global Market (ADGM) should expect heightened inspections and cross-agency coordination.

Who This Applies To

The UAE’s AML/CFT regime applies to a wide range of Designated Non-Financial Businesses and Professions (DNFBPs), including:

  • Real estate brokers
  • Auditors and accountants
  • Law firms
  • Dealers in precious metals/stones
  • Trust and company service providers (TCSPs)
  • Crypto and virtual asset service providers (VASPs)

Licensed financial institutions – including payment firms, forex dealers, investment managers, and private banks – are also under close watch.

What Regulators Expect in 2025

Under the updated AML/CFT laws and EMLO directives, licensed firms are expected to:

  • Perform customer due diligence (CDD) and enhanced due diligence (EDD)
  • Identify and verify beneficial ownership (UBO)
  • Monitor for suspicious transactions and PEPs
  • Conduct sanctions screening aligned with the UAE National Sanctions List
  • Maintain audit-ready compliance records and risk assessments

Challenges Facing UAE Firms

1. Fragmented AML Systems
Many firms rely on disconnected tools that lack unified case management, increasing audit risk.

2. Manual and Offshore Data Processing
Non-local cloud providers may expose firms to data residency violations or delays in response time.

3. Regulatory Complexity
Multiple regulators with overlapping mandates mean firms must build systems that satisfy a range of agency expectations.

How iComply Supports UAE AML Compliance

iComply offers a unified KYC and AML platform built for global and local compliance—including full support for UAE-specific requirements.

1. Real-Time Identity and Entity Verification

  • Edge-based KYC verifies natural persons and legal entities locally on the device
  • No raw PII is transmitted unencrypted or stored offshore
  • Supports Arabic documents and character sets

2. Continuous AML Screening and PEP Monitoring

  • Screen clients and transactions against UAE and global sanctions lists
  • Detect politically exposed persons and adverse media in real time
  • Configure frequency and thresholds by client type and jurisdiction

3. UBO Discovery and Documentation

  • Map complex corporate structures and nominee owners
  • Collect and validate supporting documents with automated triggers
  • Maintain evidence of CDD and EDD per risk category

4. Centralized Case Management

  • Document onboarding, screening, investigations, and decisions in one secure portal
  • Export audit logs for inspections by EMLO, SCA, DFSA, or ADGM

5. UAE-Compliant Deployment Options

  • Host data within the UAE to meet local data sovereignty laws
  • Full multilingual support, including Arabic
  • Consent management and document retention controls included

Case Insight: Payment Processor in Dubai

A DIFC-licensed payments firm adopted iComply for KYC and AML compliance. Results in 90 days:

  • Automated verification for 100% of onboarding cases
  • Reduced average review time from 2 days to under 30 minutes
  • Received positive feedback during DFSA audit with no findings

2025 Regulatory Outlook

  • EMLO Inspections: Random and risk-based audits will intensify across sectors
  • UAE Sanctions Enforcement: New alignment with international partners will expand list coverage
  • Risk-Based Program Mandates: Regulators will expect documented risk assessments and justifications for CDD scope

Take Action

Whether you’re a VASP, DNFBP, or financial institution, the bar for AML compliance in the UAE has never been higher. Leading firms are already investing in scalable, privacy-first solutions.

Contact iComply to learn how our platform helps UAE-regulated entities stay compliant, secure, and audit-ready in 2025 and beyond.

Vaidyanathan Chandrashekhar

Vaidyanathan Chandrashekhar

Advisors

“Chandy,” is a technology and risk expert with executive experience at Boston Consulting Group, Citi, and PwC. With over two decades in financial services, digital transformation, and enterprise risk, he advises iComply on scalable compliance infrastructure for global markets.
Thomas Linder

Thomas Linder

Advisors

Thomas is a global tax and compliance expert with deep specialization in digital assets, blockchain, and tokenization. As a partner at MME Legal | Tax | Compliance, he advises iComply on regulatory strategy, cross-border compliance, and digital finance innovation.
Thomas Hardjono

Thomas Hardjono

Advisors

Thomas is a renowned identity and cybersecurity expert, serving as CTO of Connection Science at MIT. With deep expertise in decentralized identity, zero trust, and secure data exchange, he advises iComply on cutting-edge technology and privacy-first compliance architecture.
Rodney Dobson

Rodney Dobson

Advisors

Rodney is the former President of ADP Canada and international executive with over two decades of leadership in global HR and enterprise technology. He advises iComply with deep expertise in international service delivery, M&A, and scaling high-growth operations across regulated markets.
Praveen Mandal

Praveen Mandal

Advisors

Praveen is a serial entrepreneur and technology innovator, known for leadership roles at Lucent Bell Labs, ChargePoint, and the Stanford Linear Accelerator. He advises iComply on advanced computing, scalable infrastructure, and the intersection of AI, energy, and compliance tech.
Paul Childerhose

Paul Childerhose

Advisors

Paul is a Canadian RegTech leader and founder of Maple Peak Group, with extensive experience in financial services compliance, AML, and digital transformation. He advises iComply on regulatory alignment, operational strategy, and scaling compliance programs in complex markets.
John Engle

John Engle

Advisors

John is a seasoned business executive with senior leadership experience at CIBC, UBS, and Accenture. With deep expertise in investment banking, private equity, and digital transformation, he advises iComply on strategic growth, partnerships, and global market expansion.
Jeff Bandman

Jeff Bandman

Advisors

Jeff is a former CFTC official and globally recognized expert in financial regulation, fintech, and digital assets. As founder of Bandman Advisors, he brings deep insight into regulatory policy, market infrastructure, and innovation to guide iComply’s global compliance strategy.
Greg Pearlman

Greg Pearlman

Advisors

Greg is a seasoned investment banker with over 35 years of experience, including leadership roles at BMO Capital Markets, Morgan Stanley, and Citigroup. Greg brings deep expertise in financial strategy and growth to support iComply's expansion in the RegTech sector.
Deven Sharma

Deven Sharma

Advisors

Deven is the former President of S&P and a globally respected authority in risk, data, and capital markets. With decades of leadership across financial services and tech, he advises iComply on strategic growth, governance, and the future of trusted data in AML compliance.