The UAE's exit from the FATF grey list in February 2024 was hard-won, and the AML/CFT obligations that took the country off the list have only intensified. Under Cabinet Decision 74/2020 on Targeted Financial Sanctions, every reporting entity in the UAE — and that includes a wide range of Designated Non-Financial Businesses and Professions (DNFBPs) like real-estate brokers, dealers in precious metals, lawyers, accountants, and corporate service providers — must screen counterparties against the UAE Cabinet TFS list, the UN Security Council consolidated list, and apply freezing measures within hours of any positive match. Doing this manually with a Friday-afternoon spreadsheet review isn't going to pass a Ministry of Economy inspection. HIBR ERP's AML/CFT TFS Screening module runs the check at the moment of onboarding, refreshes the lists every day, and produces the audit trail a regulator expects to see.
How it works
- Multi-list real-time screening. Every customer and supplier (and their UBO chain on Enterprise) is screened in real time against the UAE Cabinet TFS list, the UN Security Council consolidated list, the US OFAC SDN list, the EU consolidated financial sanctions list, the UK HM Treasury list, and an internal Politically Exposed Persons (PEP) database. Lists are refreshed daily from primary sources.
- Fuzzy matching with confidence scoring. Names, aliases, dates of birth, and identifying numbers are matched with phonetic and edit-distance algorithms. Each potential hit receives a confidence score; high-confidence matches block onboarding immediately, low-confidence matches surface as warnings for manual review.
- UBO chain screening. On Enterprise, HIBR screens not just the direct counterparty but the full Ultimate Beneficial Owner chain captured in the UBO Register module, in line with the MoE UBO regulations.
- Continuous monitoring. Every customer and supplier is rescreened daily against the refreshed lists. If a previously-clean party appears on a new list, HIBR alerts the designated Money Laundering Reporting Officer (MLRO) immediately and (where required) blocks new transactions.
- Audit trail and SAR workflow. Every screening request, every hit, every disposition decision is captured in an immutable audit trail. For confirmed hits, HIBR prompts the MLRO to file a Suspicious Activity Report (SAR) via the UAE Financial Intelligence Unit's goAML portal, with the supporting evidence pre-packaged.
- High-risk-customer enhanced due diligence. For customers in higher-risk categories (PEPs, customers from FATF-listed jurisdictions, complex ownership structures), HIBR prompts for enhanced due diligence documentation and stores it in the Document Vault.
UAE compliance details
The AML/CFT module is built around the UAE's federal AML/CFT framework and the sectoral guidance from the Ministry of Economy and the FIU:
- Cabinet Decision 74/2020 on the Implementation of UNSC Resolutions and Targeted Financial Sanctions — establishes the obligation to freeze without delay assets associated with sanctioned parties and to screen customers against TFS lists. HIBR's real-time screening and freezing prompts are designed to meet "without delay" in operational terms.
- Federal Decree-Law 20/2018 on Anti-Money Laundering and Combating the Financing of Terrorism — the umbrella AML/CFT law. Reporting obligations, customer due diligence (CDD), and recordkeeping all flow from this Decree-Law.
- Cabinet Decision 10/2019 on the Executive Regulation of the AML/CFT Decree-Law — defines CDD requirements, recordkeeping periods (5 years post-transaction), and the role of MLRO. HIBR's CDD capture and 5+ year retention align.
- Ministerial Decision 533/2021 on Specific Requirements for DNFBPs — defines tailored requirements for real estate, precious metals dealers, lawyers, accountants, and corporate service providers. HIBR's DNFBP profile applies these.
- FIU goAML reporting — HIBR pre-packages the SAR payload in the format the UAE FIU's goAML system expects, reducing reporting friction.
Tier availability
AML/CFT TFS screening is available on Pro (499/month) and Enterprise (14,990/year). Pro covers customer and supplier screening against all primary lists with daily refresh. Enterprise adds UBO chain screening, PEP enhanced due diligence workflows, the goAML SAR pipeline, and configurable risk-scoring engines for sector-specific calibration. The Lite tier does not include AML — it's aimed at single-operator businesses that typically fall outside DNFBP scope; if you become subject to AML obligations, you'll need Pro at minimum.
Use case
Frequently asked questions
Do I need to do AML/CFT screening if I'm a normal retail business?
Generally no — pure retail outside the DNFBP categories has lower obligations. But if you trade in precious metals, real estate, corporate services, audit, legal, or accept cash above 55,000 per transaction, AML/CFT obligations apply. Speak to your legal advisor; HIBR's screening is available regardless.
How often are the sanctions lists refreshed?
Daily. The UAE Cabinet TFS list, UN Security Council list, OFAC SDN, EU consolidated list, and UK HMT list are pulled from primary sources nightly. Critical interim updates (e.g., a UN Security Council emergency listing) are pushed within hours.
If I file an SAR via HIBR, does that satisfy my obligation?
HIBR pre-packages the SAR in the goAML-required format and stores the proof of filing. The actual submission via goAML and any follow-up correspondence with the FIU remain your responsibility as the regulated entity — HIBR is the tool, not the filer.
AML/CFT screening that's ready for a Ministry of Economy inspection
UAE Cabinet TFS, UN, OFAC, EU, UK HMT lists screened in real time. Audit trail, SAR workflow, UBO chain coverage. Beta launches October 2026.
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