When it comes to Anti-Money Laundering (AML) compliance in the UAE, the stakes are high. The Ministry of Economy has outlined 41 specific violations that can cost your business up to AED 1 million each. For real estate firms and other DNFBPs (Designated Non-Financial Businesses and Professions), these penalties aren't just theoretical, they are issued regularly. So how do you avoid them? It starts by choosing AML software that's not just "compliant," but engineered to help you meet the exact requirements that get companies in trouble.
In this guide, we reverse-engineer what excellent AML software must offer — based on the actual violations that cause fines. If you're evaluating a solution, make sure it checks these boxes.
1. Outdated or Missing Policies
Common Violation: No formal AML policy, or failure to update it as risk exposure evolves (Violations 1–4, 41).
What to Look For:
- Policy management templates aligned with UAE laws
- Update reminders & approval workflow logs
- Internal checklist to ensure Article (20) compliance
InfoAML Insight: Advisory services include policy drafting, and the system already allows users to manage and store AML policies directly within the built-in Document Management System. Clients can upload, organize, and control access to their compliance policies and related documents securely and efficiently
2. Weak Risk Assessment Practices
Common Violation: Failure to assess and document internal and customer risk (Violations 5–8, 15–17).
What to Look For:
- Customer & business-level risk scoring
- Risk factor tagging (geography, customer type, product)
- Auto-adjusted risk levels with audit trails
InfoAML Insight: Includes automated risk scoring and customizable rules. Strong in this area.
3. Incomplete CDD and UBO Tracking
Common Violation: Missing ID verification, UBO declarations, or proof of purpose (Violations 9–14, 19–20).
What to Look For:
- KYC/CIP data capture (ID, license, passport)
- UBO structure documentation or a simple ownership chart that shows who ultimately controls the business — including uploaded documents or visual diagrams such as tree-style charts or ownership flow diagrams connecting shareholders to the main company
- CDD checklist interface with visual completion indicators (such as check marks or status bars) within the client profile screen, helping compliance staff ensure all required steps—like ID verification, UBO declaration, and purpose of business—are fulfilled before proceeding
InfoAML Insight: Fully supports CDD documentation, verification status, and multilingual ID handling.
4. Failure to Screen or Freeze
Common Violation: Missing sanctions screening or delayed freeze actions (Violations 27–40).
What to Look For:
- Automatic updating of the latest UAE and UN sanctions lists — the minimum regulatory requirement — with the flexibility to include other widely-used sanctions sources for stronger coverage and reduced false negatives
- Screening not only against current sanctions lists but also against delisted entities, helping ensure that previously matched names are accurately cleared
- Match alert with freeze/unfreeze logs
- Tools to document and explain decisions — such as why a match was cleared or funds were not frozen.
InfoAML Insight: Real-time sanctions & PEP screening with bulk upload. InfoAML also supports matching against delisted lists to avoid unnecessary alerts. Justifications for clearing or freezing decisions are handled during the risk assessment process, where assessors append timestamped, non-deletable notes and must provide a summary before closure. This final summary becomes part of the SAR/STR report if applicable. Freeze control interface coming soon.
5. Improper Disclosure & Reporting
Common Violation: Tipping off clients or failing to report internally (Violations 28–29, 37–40).
What to Look For:
- Internal SAR/STR draft reports
- Non-reportable PER (PEP Evaluation Report)
- Alerts for disclosure violations
InfoAML Insight: STR/SAR generation is included. PER reporting and suppression controls are on the roadmap.
6. No Active Compliance Officer Role
Common Violation: Failure to appoint or empower a Compliance Officer (Violations 21, 24–25).
What to Look For:
- Dashboards with compliance-related statistics and drill-down insights — ideally, these are tailored by user role (e.g., compliance officers see alerts and overdue tasks, while managers see overall risk trends)
- Escalation workflow — the system should allow compliance tasks or alerts (e.g., a high-risk match or missing document) to be assigned and escalated to higher authority if unresolved within a set timeframe
- Compliance calendar & duty logs — a built-in calendar to track recurring tasks like policy updates, document renewals, or STR filing deadlines; duty logs help track who reviewed or approved key compliance actions and when
InfoAML Insight: Currently provides a unified dashboard with compliance statistics and filters. Role-based dashboards — tailored to specific user responsibilities — are planned for future development.
Conclusion
Choosing AML software isn’t about features, it’s about protection. Real estate businesses in the UAE face a regulatory minefield. The right AML system isn’t just a tool; it's your shield.
InfoAML is built specifically for UAE DNFBPs, mapping its features directly to real-world violations. Whether you're submitting reports, screening clients, or managing compliance documentation, every module is designed to reduce your exposure to fines.
Ready to protect your business from penalties? Book a Free Demo!
This article is based on Cabinet Resolution No. (71) of 2024 and current UAE AML enforcement trends.
Download Resources:
Download Full Cabinet Resolution No. (71) of 2024 as PDF
Download Summary Table of 41 Violations and Fines (PDF)
You might find the following related blogs helpful:
→ How to Choose AML Software in the UAE: 5 Factors That Matter
→ AML Compliance Solutions in UAE: What to Look For, What to Avoid, and What Actually Works
Looking for an all-in-one platform to manage UAE AML compliance solution?
👉 Explore our AML Compliance Solution for UAE