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ESR & AML Compliance UAE — Economic Substance & Anti-Money Laundering Services by SUM

SUM provides comprehensive ESR (Economic Substance Regulation) notifications, annual filings, and audit-ready documentation — alongside end-to-end AML/CFT compliance programmes, GoAML registration for DNFBPs, and ongoing compliance monitoring across all UAE emirates and free zones.

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About Our Service

About SUM's ESR & AML Compliance UAE

Two regulatory pillars define the UAE's international reputation as a transparent, compliant financial centre: Economic Substance Regulations (ESR) and Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) compliance.

SUM is a specialist ESR and AML compliance firm with proven expertise across mainland UAE, free zones, and designated zones. Our team includes regulatory affairs professionals, financial crime specialists, and legal experts who provide end-to-end compliance support.

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ESR & AML Specialists — UAE

ESR Services

ESR Applicability Assessment — Determine Whether Your Business is In Scope

Annual ESR Notification Filing (Ministry of Finance EmaraTax Portal)

Annual ESR Report Filing — Detailed Substance Evidence Submission

ESR Audit-Ready Documentation & Substance Evidence File Preparation

ESR Remediation Advisory — Structuring & Achieving Full Substance Compliance

ESR Penalty Defence & Regulatory Correspondence Management

AML/CFT Services

AML/CFT Compliance Programme Design & Written Policy Development

Business-Wide AML Risk Assessment & Customer Risk Classification

AML Compliance Officer (MLRO) Support & Deputy MLRO Advisory

GoAML Registration for DNFBPs (Real Estate, Gold & Precious Metals, Legal, Accounting, CSPs)

Suspicious Transaction Report (STR) & Suspicious Activity Report (SAR) Preparation & Filing

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD) Framework Implementation

AML Staff Training & Senior Management Awareness Programmes

Ongoing AML Compliance Monitoring & Annual Review

FIU Inquiry & Regulatory Examination Support

Why Dubai Businesses Trust SUM

In-depth knowledge of UAE Cabinet Decision No. 57 of 2020 (ESR) and all subsequent amendments

AML/CFT expertise fully aligned with FATF Recommendations and UAE Federal Decree-Law No. 20 of 2018

Experienced GoAML team — proficient in STR/SAR filing protocols and FIU engagement

Compliance expertise across CBUAE, SCA, RERA, DMCC, DIFC, and free zone AML directives

Proven track record with real estate agents, gold traders, lawyers, accountants, and corporate service providers

Comprehensive, audit-ready documentation prepared to withstand regulatory examination

Industries We Serve Across Dubai & UAE

Real Estate Agents, Brokers & Developers

RERA-regulated DNFBPs

Gold, Diamond & Precious Metals Traders

DMCC, Dubai Gold Souk operators

Lawyers, Notaries & Legal Consultants

Advocates and legal professionals

Accountants, Auditors & CSPs

DNFBP-covered professionals

Holding Companies & Investment Vehicles

Conducting ESR Relevant Activities

Intellectual Property Holding Companies

ESR in-scope entities

Distribution, Service Centre & Finance Entities

ESR in-scope activities

Financial Institutions & Exchange Houses

CBUAE-regulated entities

Our Process

SUM's ESR & AML Compliance UAE Process

A clear, structured approach to ESR and AML compliance that keeps your business protected and audit-ready.

Applicability Assessment

SUM assesses whether your business conducts any of the nine ESR Relevant Activities and whether it falls within DNFBP AML/CFT obligations — providing a clear written applicability opinion.

ESR Notification Filing

We prepare and file your Annual ESR Notification via the Ministry of Finance EmaraTax portal within the regulatory deadline, correctly declaring your relevant activity status and substance position.

Substance Evidence Gathering

For in-scope entities, SUM gathers and organises substance evidence: UAE-sourced income, qualified UAE-based employees, operating expenditure, physical premises records, and board meeting documentation.

ESR Report Submission

We prepare and submit the detailed Annual ESR Report — financial data, activity analysis, substance indicators, and supporting schedules — providing a complete audit-ready evidence file.

AML Programme Design

For DNFBPs and regulated entities, SUM designs a tailored AML/CFT programme: risk appetite statement, written AML policy, CDD/EDD procedures, STR/SAR protocols, and annual training calendar.

GoAML Registration & Monitoring

SUM completes GoAML registration with the UAE FIU, establishes reporting workflows, and provides ongoing compliance monitoring, annual risk assessment updates, and staff training refreshers.

Frequently Asked Questions — ESR & AML Compliance UAE

UAE ESR (Cabinet Decision No. 57 of 2020 as amended) requires UAE entities that conduct one or more of nine Relevant Activities — banking, insurance, investment fund management, lease-finance, headquarters, shipping, holding company, intellectual property, and distribution/service centre — to demonstrate adequate economic substance within the UAE.

All UAE onshore and free zone entities carrying out one or more ESR Relevant Activities must file an Annual ESR Notification — regardless of whether they meet the substance test. Even entities that claim exemption must file to declare that exemption. Non-filing penalties reach AED 20,000 for a first offence.

Designated Non-Financial Businesses or Professions (DNFBPs) include real estate agents, gold and precious metals traders, lawyers, notaries, accountants, and corporate service providers. UAE Federal Decree-Law No. 20 of 2018 imposes full AML/CFT obligations on DNFBPs: GoAML registration, customer due diligence, ongoing monitoring, and mandatory STR filing.

GoAML is the UAE Financial Intelligence Unit's (UAEFIU) digital platform for filing Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs). All DNFBPs and financial institutions in the UAE are required to register on GoAML. Failure to register or to file required reports carries criminal and administrative penalties.

ESR penalties include: AED 20,000 for late or non-filing of the ESR Notification; AED 50,000 for failure to file the Annual ESR Report; AED 400,000 for inaccurate or misleading reports or repeated violations; and potential spontaneous exchange of financial information with the entity's foreign parent jurisdiction tax authority.

Under UAE Federal Decree-Law No. 20 of 2018, AML violations can result in fines of up to AED 1,000,000 per offence for organisations, licence cancellation or suspension, criminal prosecution of the Compliance Officer or senior management, and regulatory blacklisting. Enforcement has intensified significantly since the UAE's FATF Action Plan commitments.

UAE regulators recommend a minimum of annual AML risk assessments, with interim updates required when there are material changes to business activities, new customer segments, product or service launches, significant regulatory guidance updates, or adverse findings from internal or external reviews.

Serving Businesses Across Dubai, UAE & All Free Zones

SUM provides ESR and AML/CFT compliance services across all UAE jurisdictions: Dubai (DED, DMCC, DIFC, JAFZA, Meydan, DSO), Abu Dhabi (ADGM, KIZAD, Khalifa City), Sharjah, RAK (RAKEZ), Fujairah, Ajman, and Umm Al Quwain. We serve clients across all nine ESR Relevant Activity categories and all DNFBP classifications.

DED — Dubai Mainland DMCC DIFC JAFZA Meydan Free Zone DSO ADGM KIZAD RAKEZ Sharjah Fujairah Ajman

Get Started with SUM Today

Stay ahead of UAE's evolving ESR and AML regulations. SUM's specialist compliance team is ready to assess your obligations and build a robust, audit-ready compliance framework for your business.

+971 58 122 5755 ae.sumtax@gmail.com

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