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Legal & compliance

Legal and compliance: what gets checked, and what gets punished

Compliance is not a lawyer's subject until it becomes a suspension-of-business subject. Here is what is actually checked.

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In short

Every company must keep a register of ultimate beneficial owners. Designated non-financial businesses and professions must register on the goAML portal: the Ministry of Economy suspended 50 establishments for 3 months for failing to do so, and issued 65.9 million AED in fines to 137 companies in a single quarter.

01What actually gets checked

Anti-money laundering is where the penalties really land, and land fast. Designated non-financial businesses and professions — real estate brokers, dealers in precious metals and stones, accountants, corporate service providers — must register on the goAML portal to report suspicious transactions. The legal framework in force is Federal Decree-Law No. 10 of 2025.

The figures published by the Ministry of Economy give the measure: fifty establishments suspended for three months for failing to register, and 65.9 million AED in fines issued to 137 companies in a single quarter. This is not paperwork.

02Register of ultimate beneficial owners

Every company must keep and file a register of its ultimate beneficial owners with the relevant registrar, and keep it up to date at every change of shareholding. We do not quote the matching fines: we found no accessible government source giving current amounts, and we would rather state nothing than repeat a second-hand figure.

03The contracts that really matter

In practice, four documents prevent almost every dispute a young company runs into: the shareholders' agreement, the terms and conditions of sale, an employment contract that follows the MOHRE template, and a non-disclosure agreement before any serious commercial discussion.

We do not draft those documents — we are not a law firm. We put you in touch with a licensed adviser, and we tell you their fee before you commit.

Frequently asked questions

What is goAML and who has to register on it?
It is the national portal for reporting suspicious transactions. Designated non-financial businesses and professions must register on it: real estate brokers, dealers in precious metals and stones, accountants and auditors, corporate and trust service providers.
What are the penalties for failing to register for AML?
The Ministry of Economy suspended the activity of fifty establishments for three months for failing to register on goAML, and issued 65.9 million AED in fines to 137 companies in a single quarter of 2023.
Do you have to declare ultimate beneficial owners?
Yes. Every company must keep a register of its ultimate beneficial owners and file it with the relevant registrar, updating it at every change of shareholding.
Does Oh My Desk provide legal advice?
No. We are not a law firm and we draft no legal documents. We put you in touch with licensed advisers in the UAE, who invoice their work directly.
Which text governs anti-money laundering today?
Federal Decree-Law No. 10 of 2025 is the framework in force.
Does my company count as a designated non-financial business?
It does if you are a real estate broker, a dealer in precious metals and stones, an accountant or auditor, or a corporate and trust service provider. Those professions must register on the goAML portal to report suspicious transactions.
What are the fines for failing to file the register of beneficial owners?
We do not quote a figure. We found no accessible government source giving current amounts, and we would rather state nothing than repeat a second-hand number on a page about compliance. Your registrar will give you the applicable schedule.
When must the register of beneficial owners be updated?
At every change of shareholding. The register must be kept, filed with the relevant registrar and kept up to date — it is not a one-off formality at incorporation.
Which documents prevent most disputes?
Four: the shareholders' agreement, the terms and conditions of sale, an employment contract that follows the MOHRE template, and a non-disclosure agreement signed before any serious commercial discussion.
Who drafts my contracts if you do not?
A licensed adviser we put you in touch with. We draft no legal documents, and we tell you the adviser's fee before you commit.

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