What this guidebook covers
High-value cars attract dirty money. The 2025 AML law raised fines to AED 5,000,000 per violation (up to AED 100 million in total) for supervised businesses and made managers personally liable. Whatever the scope, sanctions screening and freezing apply to every business in the UAE.
This guidebook covers the 5 AML and sanctions standards for dealer groups, with 14 checkpoints: assessing whether you are supervised, sanctions screening, customer due diligence, suspicious transaction reports, and training and records.
The 5 AML and sanctions standards
| Code | Standard | Ideal fix time |
|---|---|---|
| AM-01 | AML scope assessed | 30 days |
| AM-02 | Sanctions screening | Immediate |
| AM-03 | Customer due diligence | Immediate |
| AM-04 | Suspicious transactions reported | Immediate |
| AM-05 | Training and records | 30 days |
How to run a UAE AML and sanctions audit, step by step
- Confirm what applies. Decide whether each entity is a supervised business under current designations (take legal advice); sanctions duties apply either way.
- Walk the site, standard by standard. Score each of the 14 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Sample cash and high-value sales and check each buyer was identified and screened before the sale.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: screening results, ID copies, the scope assessment, report records and training logs.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Dealer principals and GMs
- Finance and sales managers
- Compliance officers
- Auditors
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
