The Financial Action Task Force removed the UAE from its list of jurisdictions under increased monitoring, the grey list, on 23 February 2024. The European Parliament did not block the Commission's decision to remove the UAE from the EU high-risk third-country list in July 2025. Anti-money laundering duties for UAE businesses remain in force.
The FATF decision
The UAE had been on the FATF grey list since March 2022. On 23 February 2024 the FATF removed it, after finding that the UAE had addressed the action items set for it. The reforms described in public commentary include a dedicated executive office for anti-money laundering and counter-terrorist financing, a specialist financial crime court, tighter guidance for financial institutions and designated non-financial businesses, and wider supervision. The FATF's own statements are the primary source; read them for the exact findings.
The EU high-risk list
The EU kept the UAE on its own list of high-risk third countries for some time after the FATF decision, citing judicial cooperation concerns. Law firm summaries report that the European Parliament voted on 9 July 2025 and did not block the Commission's delegated act that removes the UAE. Check the Official Journal of the EU for the date the removal took legal effect.
What may change for businesses
| Area | Likely effect |
|---|---|
| EU bank due diligence | Enhanced checks tied to the listing should no longer be required on that ground alone |
| Cross-border payments | Fewer delays are expected, but each bank sets its own risk policy |
| Account opening | Commentators expect a smoother process; banks still apply their own KYC |
| Reputation with partners | Easier conversations with foreign counterparties |
Most impact claims come from law firms and consultancies, so treat them as expectations, not measured outcomes. There is no published data we can cite on account approval rates after the decision.
What has not changed
- UAE financial institutions and designated non-financial businesses still must run customer due diligence and monitor transactions.
- Companies must keep their UBO registers current. See UBO register requirements.
- Targeted financial sanctions screening continues. See sanctions screening for businesses.
- Fines for failures remain; see AML fines for DNFBPs.
Banking in practice
A corporate bank decides to open an account based on your ownership, activity, source of funds and documents, not on the country's list status alone. Prepare a clear business plan, supporting contracts and clean accounts. We advise on preparing the file; the bank makes the decision. See corporate bank account approval and offshore corporate bank accounts.
Steps to take now
- Check that your UBO register matches your actual ownership.
- Update your customer and supplier due diligence files.
- Keep contracts, invoices and payment records aligned.
- Review who in the business owns AML and sanctions duties.
The timeline in brief
| Date | Event |
|---|---|
| March 2022 | The FATF places the UAE under increased monitoring |
| 23 February 2024 | The FATF removes the UAE from the grey list |
| July 2025 | The European Parliament does not block removal from the EU high-risk list |
Dates are from public reports; confirm them against the FATF and EU publications if you quote them.
What your customers and suppliers may ask
Foreign customers who dealt with UAE firms under enhanced checks may now ask fewer questions, but the standard questions remain: who owns the company, who controls it, what it does and where its funds come from. A tidy file answers all of these in one pack. Include the licence, the shareholder register, the UBO declaration, a short description of the business and the audited accounts if you have them.
The risk-based approach did not go away
The FATF decision recognised progress. It did not turn compliance into a one-off project. Supervisors continue to inspect, and designated non-financial businesses such as real estate agents, dealers in precious metals and stones, accountants and company service providers are examined on their own controls. A firm that has relaxed its procedures because the country left the list is taking a risk it does not need to take. See AML fines for DNFBPs.
Working with your bank
Be ready for periodic review. Banks refresh customer information, ask about unusual transactions and request updated ownership details. Answer promptly, and make sure the ownership information the bank holds matches your UBO filing. Mismatch is a common cause of account friction.
A short review you can do this quarter
- Compare the shareholder register, UBO declaration and bank KYC for differences.
- Check that the person named in each is current.
- Test whether your high-risk customers and suppliers are identified and reviewed.
- Confirm who in the business holds the compliance responsibility.
What a regulator or counterparty may ask for
When someone asks for evidence of your AML posture, they usually want a short list: your ownership chart and UBO filing, your customer due diligence procedure, your sanctions screening procedure, the name of your compliance officer, your training record and the results of any internal or external review. Prepare these as a single folder you can share. A business that can produce them in an afternoon is treated differently from one that needs a month.
Designated non-financial businesses
If you are an estate agent, a dealer in precious metals or stones, a company service provider, a lawyer, a notary or an accountant performing certain activities, you have direct AML duties, including registering with the supervisor and the goAML system and reporting suspicious transactions. Check the supervisor's guidance for your sector. The consequences of falling behind can be severe; see AML fines for DNFBPs.
Cash and high-value transactions
Cash-intensive businesses and high-value deals attract attention. Keep records of how large payments were made and by whom, and know the reporting thresholds that apply to your sector. If a customer proposes to pay a large sum in a way that does not fit their profile, treat that as a red flag and escalate.
Trade finance and cross-border payments
For businesses that import, export or re-export, banks look at the goods, the route, the counterparties and the pricing. Contracts, invoices, shipping documents and payment records should tell the same story. Differences between them draw questions. See customs duty and import tax.
Frequently asked questions
On 23 February 2024. It had been on the list since March 2022.
Law firm summaries report that the European Parliament did not block the removal in July 2025. Check the EU Official Journal for the legal effect date.
It may help, but each bank sets its own KYC and risk rules. Documents, activity and source of funds still decide.
Yes. Regulated entities and designated non-financial businesses must keep complying with customer due diligence, reporting and sanctions rules.
Yes. Companies must keep beneficial ownership information accurate and filed with the relevant authority.
On the FATF website, which publishes the plenary outcome statements, and the EU Official Journal for the EU decision.