Trust and Company Service Providers (TCSPs) are a vital part of the UAE’s business services landscape. From company formation and nominee arrangements to administrative services, TCSPs facilitate high-value transactions and asset structuring—functions that, if misused, can enable money laundering and other financial crimes.

Recognizing these risks, the UAE classifies TCSPs as Designated Non-Financial Businesses and Professions (DNFBPs), requiring them to implement and maintain strong AML/CFT compliance frameworks. As the regulatory environment continues to evolve, 2025 brings a renewed focus on UBO transparency, reporting obligations, and technological adoption.

Why AML Risk Is High for TCSPs

TCSPs can be exploited for:

  • Creating complex company structures to obscure beneficial ownership
  • Facilitating asset movement across borders with minimal traceability
  • Offering nominee services that mask true control
  • Setting up trusts or shell entities in tax havens

Without robust internal checks, these services can become high-risk conduits for illicit financial flows.

Top AML Compliance Priorities for TCSPs in the UAE (2025)

1. Implementing Risk-Based Customer Due Diligence (CDD)

Effective AML compliance starts with risk-based onboarding. TCSPs must:

  • Verify clients’ identities and business activities
  • Establish the legitimacy of the structure’s purpose
  • Identify any Politically Exposed Persons (PEPs) or high-risk jurisdictions
  • Categorize clients into low, medium, or high-risk tiers

2. Strengthening UBO Compliance

Increased regulatory scrutiny makes UBO compliance in the UAE a top priority. TCSPs must:

  • Collect and verify beneficial ownership documentation
  • Maintain a transparent and up-to-date UBO register
  • Report ownership structures when required by the UAE Ministry of Economy or regulatory authorities

AML software for TCSPs in the UAE, like WinGuardAML, supports structured UBO tracking and alerts for incomplete or high-risk profiles.

3. goAML Registration and Suspicious Reporting

TCSPs must be registered on the goAML platform and submit:

  • Suspicious Transaction Reports (STRs)
  • Suspicious Activity Reports (SARs)

Delays or non-submission may result in penalties or reputational damage. AML solutions can assist with:

  • Case management
  • Red flag detection
  • Report drafting based on structured compliance workflows

4. Ongoing Monitoring and Real-Time Screening

Due diligence doesn’t stop at onboarding. TCSPs should screen clients and counterparties on an ongoing basis, checking against:

  • Sanctions and watchlists (OFAC, UN, EU)
  • PEP databases
  • Adverse media and risk indicators

AML software for TCSPs in the UAE automates these checks, reducing manual effort and ensuring regulatory alignment.

5. Internal Controls, Audit Trails, and Staff Training

2025 calls for greater accountability within TCSP operations. Compliance frameworks should include:

  • Appointment of a dedicated Compliance Officer
  • Written AML/CFT policies and procedures
  • Routine internal audits and reviews
  • Training staff to recognize and escalate suspicious behavior
Conclusion

In an increasingly regulated environment, AML compliance is not just about avoiding penalties—it’s about protecting your business, your clients, and the UAE’s reputation as a safe and transparent financial center.

TCSPs must embrace risk-based frameworks, maintain UBO compliance, and adopt intelligent tools to streamline processes. Platforms like WinGuardAML, purpose-built as AML software for TCSPs in the UAE, help automate client screening, risk profiling, and ongoing monitoring—ensuring your firm is audit-ready and regulator-aligned.