AML Compliance in UAE: A Guide to Record-Keeping of Customer Identity and Transactions

As per Article 24 of Cabinet Decision No. (10) of 2019, Financial Institutions (FI) and Designated Non-Finance Businesses & Professions (DNFBPs) are required to maintain proper records to ensure compliance with Anti-Money Laundering and Combatting Financing of Terrorism (AML-CFT). FIs & DNFBPs are required to maintain all records, documents, data and statistics for all financial transactions and local or international commercial and cash transactions.

The AML-CFT records must be kept for not less than five years from the date of completion of the transaction or termination of the business relationship with the Customer. Failing to comply with the requirements will attract hefty penalties. Consulting with AML consultants in Dubai can help you comply with the regulations. Read ahead to know how to comply with the record-keeping requirements.

Type of Records to be Maintained 

Companies should know about the type of records they must maintain to ensure AML compliance in the UAE. However, it depends upon the regulations they are required to adhere to. Yet, the key requirement is that the FIs and DNFBPs are required to details related to the scanning, screening, and verification process. Stated below are some of the records companies must maintain:

  • Customer information
  • Transaction records
  • Annual MLRO reports
  • External & internal suspicion reports
  • Investigation records
  • Information not yet processed
  • Actions are taken following request from an authority
  • AML training registers

Key Records to Maintain for AML Compliance in the UAE 

The following records must be given importance:

Customers Information  

As part of the Customer Due Diligence (CDD) process, the companies under AML obligation are required to verify the customer’s identity maintain a copy of references,  and other relevant pieces of evidence. Companies must maintain other CDD documents such as a copy of identities and any other additional information. Such documents can be presented to the authorities when required. AML consultants in Dubai can assist you in meeting the compliance requirements.


Companies under AML obligation are required to maintain records related to business relationships- transactions from the last five years of fulfilling the transaction. The transaction records you must keep include credit and debit notes and correspondence with the specific business. Consult with AML compliance advisers in Dubai for more clarity on this requirement.

Internal and External Suspicion Reports 

FIs and DNFBPs are required to meet all the internal and external reporting requirements such as maintaining records of the transactions. You must ensure that your company has kept records of the times the MLRO has reviewed. MLRO or AML compliance officer must ensure the company complies with AML-CFT controls. The companies must handle all the information and check all the suspicious cases of money laundering, revealing the matters to law enforcement.

How to Maintain Customer Identity and transaction records? 

The procedure of record-keeping is dependent upon the local and international regulatory requirements. Some standard methods of record-keeping involve the following:

  • Keep the original documents
  • Maintain photocopies of original documents
  • Keep scanned copies of documents
  • Store the documents in electronic form
  • Keep a copy on the microfiche

How to Safely Keep the AML-CFT Records? 

You must store the records in such a way that they can be easily accessed. If the company has plans to scale or expand, you must devise a strategy to safely keep the records. You must develop an effective plan to make the records available in case of mergers and acquisitions. The guidelines do not specify a location to keep the records. However, you must ensure that they are kept in a place from where the records can be retrieved without any hassle.

Administrative Penalties Related to Record-keeping 

A penalty of AED 100,000 will be imposed on companies that fail to create records on financial transactions with the customers. An administrative penalty of 50,000 will be slapped on entities that fail to keep records of financial transactions and relevant documents for five years from the date of transaction completion, or the expiry of the business relationship with the customer.

How can Jitendra Chartered Accountants Help? 

It is mandatory for companies to keep records of customer identity and transactions to ensure AML compliance in the UAE. Furthermore, companies must meet the records to prevent the occurrence of money laundering activities. Failing to abide by AML-CFT regulations will lead to hefty administrative penalties. However, consulting with AML consultants in Dubai such as Jitendra Chartered Accountants (JCA) is the best way to ensure compliance.

JCA is one of the leading providers of AML compliance services in Dubai. We help FIs and DNFBPs with advanced AML solutions to ensure compliance. Our services include building a robust AML-CFT framework, implying AML training, and AML-CFT penalty appeal services etc.