Economic Substance and Anti-Money Laundering Basics

Economic substance: what changed

Cabinet Decision No. 98 of 2024 cancelled economic substance notifications and reports for financial years ending after 31 December 2022, as the UAE moved to corporate tax.¹

• Companies remain responsible for their obligations for earlier years.
• They must still answer information or amendment requests from regulators or the Federal Tax Authority.
• Any penalties imposed by the Federal Tax Authority must still be paid.

Source: Ministry of Finance: Amendment to the Cabinet Decision on economic substance requirements (October 2024)¹

Anti-money laundering

Federal Decree-Law No. 10 of 2025 covers money laundering, terrorist financing and proliferation financing, and Cabinet Resolution No. 134 of 2025 sets out its executive regulations. The law creates an independent Financial Intelligence Unit within the Central Bank, which receives all suspicious transaction reports.^3,4

Nobody may carry on financial activities or a designated non-financial business or profession (DNFBP) without a licence or registration from the competent or supervisory authority.³

Source: Ministry of Economy and Tourism: Combating money laundering and terrorism financing²

The ministry supervises these sectors on the mainland and in commercial free zones, and requires them to register in the goAML reporting system. Financial free zones such as DIFC and ADGM have their own regulators.²

What every company should do

• Keep the beneficial owner register up to date.
• Find out whether your activity is a DNFBP. If it is, register with your supervisor and in goAML.
• Keep the ESR filings and records for years up to 2022 in case the authorities ask.

This page is a summary. The obligations of each DNFBP sector are set out in the law, the executive regulations and the supervisor's circulars, so take advice from an accountant or lawyer.