Compliance obligations don’t arrive in a generic shape. A real estate broker, a gold dealer and a virtual asset exchange each answer to different rulebooks, different supervisors and different typologies of risk.
We build frameworks calibrated to the sector you actually operate in, and to the licence, products and customers you actually hold.
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Real Estate
Brokers, developers, property managers and real estate investment vehicles
Real estate is among the most closely scrutinised DNFBP sectors in the UAE, and enforcement is active. Brokers and developers carry full AML/CFT obligations, plus a specific reporting duty for cash and virtual asset payments that many firms only discover after a penalty notice.
Where the regulatory pressure sits
Ministry of Economy and Tourism supervision, goAML registration, and emirate-level requirements from authorities such as the Dubai Land Department and ADREC
Real Estate Activity Reports (REAR) for cash payments at or above AED 55,000 and for payments involving virtual assets
Buyer and seller CDD, including the beneficial owners of corporate purchasers
Source of funds evidence on high-value and off-plan transactions
Sanctions screening of buyers, sellers and connected parties
A compliance function that works inside a commission-driven sales culture
How RegLex helps
We register the business on goAML and build the reporting workflow
We write CDD procedures agents will actually follow at the point of sale
We deliver role-specific training to sales teams, not generic eLearning
We audit the framework and remediate back-book files before an inspection finds the gaps
Gold and jewellery traders, bullion dealers, refiners and precious stone dealers
Dealers in precious metals and stones handle high-value, portable and often cash-intensive goods that move easily across borders. Supervisors expect controls calibrated to the trade itself, its supply chains, payment methods and customers, not a banking template.
Where the regulatory pressure sits
Ministry of Economy and Tourism supervision and goAML registration
Dealers in Precious Metals and Stones Reports (DPMSR) for qualifying cash transactions at or above AED 55,000
Responsible sourcing and supply chain due diligence, particularly for gold
Trade-based money laundering: invoice, valuation and shipment red flags
Customer due diligence on walk-in, cross-border and corporate buyers
Record-keeping that stands up to a Ministry of Economy and Tourism inspection
How RegLex helps
We build the AML/CFT and CPF programme around how your trade actually runs
We design supply chain due diligence that satisfies refiners, banks and the regulator
We set up threshold reporting workflows and records on goAML
We train counter and trading staff on the red flags they will actually see
Company formation agents, corporate service providers, accountants and auditors
Corporate service providers and accounting firms are gatekeepers. They set up the structures, act for the companies and see the money, which is why supervisors treat them as DNFBPs with full AML/CFT obligations. A weak gatekeeper becomes the route through which others abuse the system.
Where the regulatory pressure sits
Ministry of Economy and Tourism supervision and goAML registration
Client due diligence on complex, layered and offshore structures
Beneficial ownership identification and record-keeping
Risk in nominee director, nominee shareholder and registered office arrangements
Red flags in company formation, restructuring and client money handling
Balancing client confidentiality with reporting obligations
How RegLex helps
We build a client acceptance and risk-rating framework proportionate to your firm
We write CDD and beneficial ownership procedures your team can apply consistently
We act as your outsourced Compliance Officer or MLRO where you need one
We carry out the independent audit of your AML/CFT framework
General traders, free zone trading companies, commodity traders and freight forwarders
Trade is where sanctions and proliferation financing risk concentrates. Dual-use goods, transhipment routes, opaque counterparties and trade finance combine into an exposure profile that free zone authorities, supervisors and correspondent banks examine closely.
Where the regulatory pressure sits
Sanctions and targeted financial sanctions exposure across counterparties, goods and routes
Dual-use goods identification and export control obligations
Proliferation financing risk assessment and red-flag typologies
Trade-based money laundering indicators: over- and under-invoicing and phantom shipments
Counterparty and agent due diligence across multiple jurisdictions
Free zone licensing conditions, AML inspections and customs compliance
How RegLex helps
We run dedicated sanctions and proliferation financing risk assessments
We build screening that covers counterparties, vessels, routes and goods
We prepare the evidence banks need to open and maintain your accounts
We support you through free zone AML inspections and respond to findings
Exchange houses, remittance providers and registered hawala providers
Exchange houses move high volumes of cross-border payments, often in cash and often through corridors that supervisors treat as higher risk. The CBUAE supervises the sector closely and has imposed significant financial sanctions on exchange houses for AML/CFT failings. A framework that looks good on paper but cannot keep pace with branch and transaction volumes will not survive an inspection.
Where the regulatory pressure sits
CBUAE licensing, capital and ongoing supervisory requirements, including the registration of hawala providers
Customer due diligence on walk-in, occasional and high-frequency customers across a branch network
Wire transfer rules: complete originator and beneficiary information on every remittance
Transaction monitoring for structuring, high-risk corridors and unusual patterns across branches
Sanctions screening of senders, beneficiaries and correspondent partners, in real time
Oversight of correspondent relationships, agents and payout partners abroad
How RegLex helps
We build AML/CFT and CPF programmes that work at branch and transaction volume
We calibrate monitoring and screening to your actual corridors and customer base
We carry out independent AML audits and prepare you for CBUAE inspections
We provide outsourced MLRO and Compliance Officer support and train branch staff
Insurers, takaful operators, insurance brokers and agents
Insurers face two demanding regimes at once: prudential and financial reporting, where IFRS 17, technical reserves and solvency are under constant scrutiny, and AML/CFT, where life, savings and investment-linked products carry real money laundering risk. Onshore insurers and brokers are supervised by the CBUAE; firms in the DIFC and ADGM answer to the DFSA and FSRA.
Where the regulatory pressure sits
CBUAE insurance regulations, or DFSA and FSRA requirements for firms in the financial free zones
IFRS 17 measurement, reporting and disclosures
Technical reserves, solvency and the Financial Condition Report
Own Risk and Solvency Assessment (ORSA) and regulatory returns to the CBUAE
AML/CFT controls for life, savings and investment-linked products, including early surrenders and third-party payments
Governance, actuarial oversight and conduct towards policyholders
How RegLex helps
We provide IFRS 17 managed services and support period-end reporting
We review and calculate technical reserves and prepare the Financial Condition Report and ORSA
We prepare CBUAE insurance regulatory returns to filing standard
We build AML/CFT programmes calibrated to your product mix and distribution channels
Securities, commodities and derivatives brokers, introducing brokers and online trading platforms
Brokers hold client money, onboard clients remotely and often market to retail investors across borders, which puts them under scrutiny from both conduct and AML/CFT supervisors. Onshore brokers are licensed by the CMA; those in the DIFC and ADGM by the DFSA and FSRA.
Where the regulatory pressure sits
Licensing scope, permissions and capital requirements under the CMA, DFSA or FSRA
Client money and client asset protection, segregation and reconciliation
Suitability and appropriateness assessments, and retail client protections
Non-face-to-face onboarding, third-party payments and source of funds for trading accounts
Market abuse surveillance and suspicious transaction and order reporting
Marketing and promotion restrictions, including cross-border offerings
How RegLex helps
We support licensing and variations of permission, and prepare prudential returns and ICAAPs where required
We build onboarding, suitability and client money frameworks that stand up to review
We provide outsourced MLRO and Compliance Officer cover with brokerage experience
We train dealing, sales and back-office teams on conduct and AML red flags
Payment institutions, stored value facility issuers, remittance and open-finance platforms
Payment and fintech businesses sit inside one of the most closely supervised perimeters in the UAE. Whether you hold a CBUAE Stored Value Facility or Retail Payment Services licence, operate from the DIFC or ADGM, or partner with a licensed institution as an agent, the regulator expects institutional-grade controls from day one, often before the first transaction settles.
The same applies to marketplaces and platforms that hold customer funds or pay out to sellers. A regulated payment activity can arise without anyone planning it.
Where the regulatory pressure sits
CBUAE Retail Payment Services and SVF licensing, or DFSA and FSRA money services authorisation
Safeguarding and client money segregation arrangements
Transaction monitoring calibrated to high-volume, low-value flows
Agent and distributor oversight, including onboarding and ongoing monitoring
Outsourcing and cloud governance for core payment infrastructure
Consumer protection, complaints handling and fee transparency
How RegLex helps
We prepare the licence application, including the regulatory business plan and financial model
We build the AML/CFT programme and calibrate monitoring to your actual payment flows
We provide interim MLRO and Compliance Officer cover through the pre-licence and scale-up phases
We test screening and monitoring effectiveness before the regulator does
Virtual asset service providers, exchanges, custodians, brokers and token issuers
The UAE has built one of the most developed virtual asset regimes in the world, and one of the most demanding. VARA in Dubai, the FSRA in ADGM, the DFSA in DIFC and the CMA for certain onshore activities each run distinct rulebooks with their own activity definitions, capital requirements and technology standards. Frameworks written for banks don’t fit.
Where the regulatory pressure sits
Licensed activity scope and conditions under the VARA, FSRA, DFSA or CMA framework
The travel rule: originator and beneficiary information on transfers between VASPs
Wallet screening, blockchain analytics and exposure to mixers and sanctioned addresses
Custody, key management, segregation and proof of reserves
Market conduct, listing and delisting controls, and market abuse surveillance
Technology governance, penetration testing and incident response
How RegLex helps
We prepare the licence application and manage regulator dialogue through to approval
We write frameworks built for on-chain risk, not adapted from banking templates
We provide outsourced MLRO and Compliance Officer cover with virtual asset experience
We test your exposure to sanctions evasion, proliferation financing and illicit flows
Fund managers, general partners, venture funds and private capital vehicles
Fund managers carry a double compliance burden: the obligations of the management entity and those attached to each vehicle it runs. Investor due diligence has tightened considerably, and institutional investors now examine the compliance function itself before committing capital.
Where the regulatory pressure sits
CMA, DFSA or FSRA fund management authorisation and fund registration
Investor CDD, source of wealth evidence and PEP handling across multiple jurisdictions
Conflicts of interest, allocation policy and personal account dealing controls
Valuation governance, NAV oversight and independent pricing challenge
Delegation and outsourcing to administrators, custodians and investment advisers
Marketing and private placement restrictions across the UAE and offshore jurisdictions
How RegLex helps
We support licensing of the manager and registration of its funds, onshore or in either financial free zone
We build the investor onboarding framework that investors will diligence without friction
We provide outsourced compliance and MLRO cover so the function is credible from first close
We prepare the prudential returns and capital adequacy documentation that sit behind the licence
Single and multi-family offices, holding structures and private investment companies
Family offices operate where privacy meets disclosure. Structures built for confidentiality now sit against beneficial ownership registration, corporate tax and tax transparency requirements, and banks increasingly decline relationships where ownership cannot be traced cleanly.
Where the regulatory pressure sits
Beneficial ownership identification and registration across layered and offshore structures
Corporate tax registration, qualifying free zone status and transfer pricing
Family office registration and licensing in the DIFC or ADGM, where applicable
Governance frameworks, family charters and delegation of authority
Bank onboarding and relationship due diligence
Succession, control and reputational risk
How RegLex helps
We map the structure, resolve the beneficial ownership position and prepare the filings
We build governance that survives generational transition and satisfies counterparties
We keep the books, tax filings and IFRS reporting consistent across the group
We advise discreetly on sensitive reviews and remediation
Insight from one sector sharpens our work in the next. Banking discipline helps fintechs scale, and lessons from virtual assets strengthen traditional DNFBPs. That wider view keeps a framework robust when your business model changes.