Regulatory notes
A short set of notes on regulatory practice, arranged by subject rather than by date. Each is revised when the framework changes; the revision date is shown on the note.
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Current instruments: a reference
The federal instruments applicable to anti-money laundering, beneficial ownership and insurance business in the United Arab Emirates, with commencement dates and what each replaced. Maintained rather than dated.
Last revised: 16 August 2026
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Beneficial ownership through the placement chain
Where a risk passes through a producing broker, a wholesale broker, a fronting insurer and one or more reinsurers, the participants do not share a single obligation. The first question is which of them the federal framework reaches at all.
Last revised: 16 August 2026
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The 2025 instruments and the insurance perimeter
General accounts of the 2025 anti-money laundering framework describe the law as a whole. For insurance and reinsurance the more consequential questions are how Article 2 classifies the person, how that classification interacts with sector-specific supervision, and which instrument supplies each obligation.
Last revised: 16 August 2026
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Sanctions checkpoints through the placement lifecycle
A sanctions review at inception records one moment in a placement. Endorsements, renewals, claims and payments introduce different parties and facts, while each participant sees only part of the chain.
Last revised: 18 August 2026
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Relying on another participant's due diligence
Where several intermediaries are involved, Article 20 permits an in-scope entity to rely on specified customer due diligence measures performed by a third party, subject to stated conditions, while retaining responsibility for their accuracy.
Last revised: 8 October 2026
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When must KYC be completed?
FATF fixes the circumstances in which customer due diligence is required and its essential components. Risk determines the proportionate depth of the measures and, within narrow national conditions, their sequencing.
Last revised: 27 August 2026
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Delegated underwriting authority: KYC for MGAs, coverholders and insureds
A binding authority creates two distinct compliance questions: who is authorised to act for the insurer, and how customer due diligence and sanctions controls are performed when risks are bound through an intermediary. The applicable perimeter has to be established before the arrangement can be characterised as third-party reliance or outsourcing.
Last revised: 8 October 2026
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