AutoSmart GuidebooksWhat 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
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
AM-01AML scope assessed30 days
- The law
- Federal Decree-Law No. 10 of 2025 on AML/CFT (in force 14 Oct 2025) · Cabinet Decision 74/2020 on targeted financial sanctions · FDL 10/2025 designated non-financial businesses and professions (DNFBPs)
- What we check
- The group has assessed whether any entity is a supervised business under the 2025 law, and if so, has registered on goAML and set up an AML programme.
- What it can cost
- If in scope and unregistered: AED 50,000-5,000,000 per violation.
- Evidence
- Legal memo
AM-02Sanctions screeningImmediate
- The law
- Federal Decree-Law No. 10 of 2025 on AML/CFT (in force 14 Oct 2025) · Cabinet Decision 74/2020 on targeted financial sanctions · Cabinet Decision 74/2020: screen, freeze and report under UAE and UN sanctions lists
- What we check
- Customers and suppliers are screened against the UAE Local Terrorist List and UN sanctions lists, and any match is frozen and reported without delay.
- What it can cost
- Sanctions breaches are among the most serious offences, with prison risk.
- Evidence
- Screening log
AM-03Customer due diligenceImmediate
- The law
- Federal Decree-Law No. 10 of 2025 on AML/CFT (in force 14 Oct 2025) · Cabinet Decision 74/2020 on targeted financial sanctions · FDL 10/2025 customer due diligence
- What we check
- For high-value and cash sales, the buyer's identity (Emirates ID or passport) is verified, the source of funds is recorded, and third-party payments are questioned.
- What it can cost
- Up to AED 5,000,000 per violation if supervised.
- Evidence
- CDD files
AM-04Suspicious transactions reportedImmediate
- The law
- Federal Decree-Law No. 10 of 2025 on AML/CFT (in force 14 Oct 2025) · Cabinet Decision 74/2020 on targeted financial sanctions · Reporting suspicious transactions to the FIU via goAML; no tipping off
- What we check
- Suspicions are escalated internally, reported to the FIU through goAML, and the customer is never tipped off.
- What it can cost
- Personal criminal liability for managers.
- Evidence
- Log
AM-05Training and records30 days
- The law
- Federal Decree-Law No. 10 of 2025 on AML/CFT (in force 14 Oct 2025) · Cabinet Decision 74/2020 on targeted financial sanctions · AML training and record keeping (at least 5 years)
- What we check
- Sales and accounts staff are trained on AML and sanctions, and records are kept for at least 5 years.
- What it can cost
- Standard findings, adding to fines of up to AED 5M.
- Evidence
- Training log
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.
