Who Is Classified as a DNFBP Under UAE AML Regulations?

Understanding whether your business is a DNFBP is critical—misclassification is one of the most common compliance failures seen by UAE regulators.

 

What Does DNFBP Mean?

A DNFBP is a non-financial business or profession that, due to the nature of its activities, is vulnerable to:

• Money laundering

• Terrorist financing

• Sanctions evasion

DNFBPs are regulated under UAE Federal AML laws and must implement risk-based AML controls similar to those of financial institutions.

 

DNFBP Categories Under UAE AML Law

The UAE AML framework clearly identifies the following businesses and professions as DNFBPs:

 

1. Dealers in Precious Metals and Stones (DPMS)

This includes businesses that trade in:

• Gold, silver, platinum, and other precious metals

• Diamonds and precious stones

Examples:

• Bullion traders

• Gold wholesalers and retailers

• Refinery-linked traders

DPMS are considered high-risk due to cash transactions, portability of assets, and cross-border trade.

 

2. Real Estate Brokers and Agents

Real estate businesses involved in:

• Buying and selling property

• Leasing and brokerage services

These firms are high-risk because real estate can be used to:

• Park illicit funds

• Layer transactions

• Conceal beneficial ownership

 

3. Company Service Providers (CSPs)

This category includes firms that:

• Incorporate or register companies

• Provide nominee directors or shareholders

• Offer registered office or address services

CSPs play a key role in corporate structuring and are vulnerable to misuse by shell companies.

 

4. Auditors and Accountants

Professional service providers offering:

• Accounting services

• Audit services

• Financial reporting

Their access to financial information places them in a position of potential misuse if controls are weak.

 

5. Lawyers, Legal Consultants, and Notaries

Legal professionals are DNFBPs when they act on behalf of clients in:

• Buying or selling real estate

• Managing client funds

• Creating or managing legal persons or arrangements

Pure litigation services generally fall outside AML scope, but transactional work does not.

 

6. Trust and Corporate Service Providers

This includes businesses managing:

• Trusts

• Foundations

• Corporate structures

These entities are closely regulated due to beneficial ownership risks.

 

Who Is Not a DNFBP?

Not every non-financial business is a DNFBP. For example:

• Pure retail businesses (non-high-value goods)

• Manufacturing companies with no customer-facing financial transactions

• Professional services with no involvement in financial or asset-related transactions

However, business activities, not trade licenses alone, determine classification.

 

Key Obligations for DNFBPs

If your business is classified as a DNFBP in the UAE, you must:

• Register on the goAML platform

• Conduct Customer Due Diligence (CDD)

• Apply Enhanced Due Diligence (EDD) where required

• Screen customers against sanctions and PEP lists

• Maintain records for at least five years

• Appoint a Compliance Officer

• Submit Suspicious Transaction/Activity Reports

Failure to comply can lead to fines, license suspension, or criminal liability.

 

Final Thought

DNFBP classification under UAE AML law is not optional or subjective. If your business activities fall within the defined categories, full AML compliance is mandatory, regardless of company size or transaction volume.

Early identification and correct classification are the first steps toward regulatory compliance and long-term business stability.