The UAE Supervisory Sub-Committee has established unified guidance on the appointment, authority, and responsibilities of the Compliance Officer/Money Laundering Reporting Officer (CO/MLRO) function across regulated sectors. This document applies to Financial Institutions (FIs), Designated Non-Financial Businesses and Professions (DNFBPs), and Virtual Asset Service Providers (VASPs) supervised by authorities including CBUAE, CMA, MOJ, MOET, DFSA, FSRA, VARA, and GCGRA. Key Guidance:

• The Reporting entities to establish a harmonized framework under Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 to strengthen AML/CFT/CPF programs, aligning with FATF standards and promoting operational independence for CO/MLROs.
• The CO/MLRO must hold senior positions with direct Board access, no conflicts of interest, and adequate resources; fit-and-proper tests are mandatory for appointments.
• The CO/ MLRO is responsible for transaction monitoring, STR/SAR review and filing, policy development, risk assessments, training programs, bi-annual reporting, and record-keeping for at least five years.
• The reporting entities to ensure compliance, with no outsourcing of the CO/MLRO role allowed (though specific tasks may be after supervisory approval).
• The guidance also identifies common compliance gaps such as inadequate oversight and reporting gaps, and urge immediate gap analysis by the reporting entities to ensure compliances.

Critical Requirements

• Seniority Required – CO/ MLRO must be Board-level with direct access and non-conflicting roles in the company.
• No Outsourcing of CO/ MLRO role – Core role stays in-house, however, certain specific AML compliance tasks like screening, due diligence etc may be selectively outsourced after authority approval.
• Fit & Proper Tests –AML expertise mandatory for CO/ MLRO. Annual review of the CO/MLRO.
• Expanded Duties – Stricter Transaction monitoring, Prompt STR filing, and bi-annual board reporting

  To understand how the new AML guidance affects your company—or to schedule an AML “health check”—please contact us at uae@mbgcorp.com