From Rules to Reality – Adapting to Dynamic Regulatory Expectations

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The first ever Customer Awareness Drive Event in UAE, jointly organized by Crowe UAE and LuLu Exchange, offered valuable insights into regulatory expectations through engaging interactions with industry leaders and academia. The high-powered panel discussion on the topic - From Rules to Reality – Adapting to Dynamic Regulatory Expectations, organised as part of the event, brought together distinguished experts who shared perspectives on evolving compliance requirements and practical approaches to effective implementation with special emphasis on Government Entities, Free Zones, Industry Bodies and business sector.

The transcripts of the discussion are provided for detailed reading and knowledge enhancement. It gives an insight into the knowledge, experience and perceptions of the speakers from various fields.

The panel discussion was moderated by Mr. Mahammad Ansar, Head of Compliance at Lulu Exchange.

Speakers in the panel included Mr. Hassan Alshaiba, Compliance Office Manager at the Department of Economic Development, Ras Al Khaimah, Ms. Ahmadeyya Mohammed Omar, Director of Compliance at Ras Al Khaimah Economic Zone (RAKEZ), Ms. Mamtha Maria Francis, General Manager of the Dubai Jewellery Group and Member of the PPPC Secretariat at the Executive Office of AML/CFT, UAE, and Mr. Aditya Prasad, Chief Executive Officer of PAMP Gold.

For Full video of Panel discussion, visit:

Round 1 – Current Scenario

Moderator: DED plays a central role in supervising DNFBPs. To start us off, could you give us a snapshot of DNFBP regulations — both globally and here in the UAE — and how the UAE positions itself within that framework?

Hassan Alshaiba: Globally, DNFBPs were first introduced in 2003 to strengthen the fight against money laundering, with risk-based supervision and obligations like customer due diligence coming in around 2012. In the UAE, the concept was formally adopted in 2018 through Federal Decree Law, with the clear objective of aligning to global standards while addressing local risks. This positions the UAE as a proactive leader in embedding international best practices and strengthening compliance across the DNFBP sector and fighting money laundering.

Moderator: Free zones attract global businesses — how do you balance ease of doing business with strict AML compliance?

Ms. Ahmadeyya: Free zones are designed to attract global businesses, but alongside that comes the responsibility of ensuring compliance. The process begins right at the onboarding stage — with KYC checks, monitoring of cash transactions, and only then the issuance of a business license. Beyond onboarding, we actively engage with existing clients by keeping them informed about new rules and regulations issued by the Decree Law, ministries, and regulatory bodies. This is done through webinars, training sessions, and informative material. Such initiatives allow free zones like RAKEZ to strike the right balance — offering ease of doing business while ensuring strict adherence to AML requirements.

Moderator: As a senior industry leader, how do you balance regulatory compliance with smooth business operations in such a fast-moving gold market?

Aditya Prasad: Compliance is not a separate activity — it’s an integral part of doing business. In a fast-moving market like gold, KYC goes far beyond just collecting documents; it’s about truly knowing your customer — their background, intentions, and transactions. Compliance is everyone’s responsibility, though it is ultimately led by the compliance officer and the leadership team. When embedded into the business process, compliance not only protects against regulatory penalties but also ensures we operate with the right partners — ethically, morally, and sustainably — which is essential for long-term success.

Moderator: How can industry associations like DGJG support their members in building stronger compliance cultures?

Ms. Mamtha: The journey to regularize the gold sector began in 2019, with regulations being formalized in 2021 right after the pandemic. At DGJG, our primary focus has been on capacity building — we’ve already trained thousands of professionals across the industry. The real challenge, however, lies in sustaining this capacity over the long term. To support our members, we take complex regulations and present them in a simplified, practical manner, making compliance easier to adopt in daily operations. With the next evaluation set for 2026, our commitment is to ensure that our members are fully prepared and able to foster a strong, lasting culture of compliance.

Round 2 – Challenges & Collaboration

Moderator: You’ve often stressed that regulation doesn’t happen in isolation. What are the ecosystem features of collaboration between UAE regulators and industry that you see as most important for building a strong compliance culture?

Hassan Alshaiba: You’re right — regulation doesn’t happen in isolation; it’s part of a larger ecosystem. In the UAE, the Higher Committee for Oversight of the National Strategy to Combat Money Laundering and Terrorist Financing, established under Federal Decree Law No. 20 of 2018 and chaired by His Highness Sheikh Abdullah bin Zayed Al Nahyan, provides the strategic oversight. Below this, national entities such as the Ministries of Economy, Justice, Finance, and the Central Bank play critical regulatory roles.

At the operational level, specialized subcommittees monitor day-to-day activities like onboarding processes and the use of screening systems, with progress reported back to the Higher Committee, which meets every 2–3 months. This layered structure ensures alignment between strategy and execution, while also fostering close collaboration with industry — an approach that is vital for embedding a strong and sustainable culture of compliance across the UAE.

Moderator: How can DNFBPs bridge the gap between theoretical AML rules and practical implementation in a fast-changing environment?

Ms. Ahmadeyya: DNFBPs can bridge the gap by focusing on understanding the essence of compliance and applying regulations in a simplified, practical manner rather than treating them as just theoretical obligations. At RAKEZ, we support our DNFBPs systematically through webinars, training sessions, and regular updates on new or amended regulations issued by the Ministry of Economy and other authorities. While continuous training for all may not always be possible, we ensure that simplified guidance is provided whenever changes occur. In addition, periodic inspections help DNFBPs strengthen their practices — from handling cash transactions to profiling clients and reporting suspicious activities — thereby making compliance more practical, actionable, and sustainable.

Moderator: How does DGJG work with regulators (DED, MOE, Free Zones) to advocate for practical and business-friendly AML compliance?

Ms. Mamtha: There are three important aspects to how DGJG works with regulators. First, in the UAE, regulators actively consult industry bodies, and the government is open to listening to the private sector. This allows us to raise practical concerns on specific clauses in rules and regulations. Second, DGJG acts as a bridge between the gold sector and regulators — we surface the real challenges businesses face, which only the industry itself can fully articulate. And third, regulators rely on industry bodies like ours to create awareness and drive adoption of compliance. For example, toolkits and guidance provided by regulators are distributed through us to member firms in an effective and practical way. In this way, we work hand in hand with regulators to make AML compliance both robust and business friendly.

Moderator: From your experience, what are the major risks gold and bullion companies face in terms of money laundering and trade-based financial crime?

Aditya Prasad: One of the biggest challenges in the gold and bullion sectors is the uneven capacity to manage compliance. Large companies can invest in human and technical resources, but many bullion and gold businesses are still small, often one-man operations, and that’s where industry bodies play a vital role. With gold prices having surged nearly 40% in the past year — meaning 100 grams, it now costs almost half a million dirhams — the risk of financial crime has also increased. A key example is smurfing, where large transactions are broken into smaller ones to avoid detection, such as buying gold in small quantities with repeated cash payments of AED 50,000. This is why training frontline employees, both in retail and B2B, is critical — they are the first line of defense in identifying and controlling such risks.

Round 3 – Practical Solutions & Future Outlook

Moderator: You mentioned that a key challenge is DNFBPs fully understanding their AML obligations. How does DED ensure that licensed businesses — from SMEs to large corporates — are aware of and implement these obligations?

Hassan Alshaiba: There are several ways we ensure DNFBPs remain compliant with regulatory requirements. First, right from the registration and licensing stage, businesses go through the standard onboarding process, which includes AML and sanctions declarations. Second, we apply risk-based supervision to focus our oversight where it’s most needed. Third, remediation is critical — during inspections, if we find gaps such as the absence of a screening solution, we immediately guide the DNFBP to fix it, addressing the issue hands-on.

We then follow up, usually after a month, to check progress and, if necessary, escalate toward penalties — but only after giving businesses the chance to understand, be educated, and improve. Our inspections take two forms: questionnaires to assess knowledge of obligations like reporting, and on-site reviews to see how businesses are actually operating. This approach balances awareness, education, and enforcement, helping both SMEs and large corporates embed AML compliance into their day-to-day operations.

Moderator: How do you encourage companies in RAKEZ to view compliance not as a burden but as a business enabler?

Ms. Ahmadeyya: At RAKEZ, building trust with our DNFBPs is our top priority, and we see compliance as central to that trust. Strong compliance keeps both the business and the country on the safer side. For example, we ensured all entities completed their goAML registration within a year, helping them avoid penalties. But beyond registration, we emphasize the ‘why’ — why compliance matters, what to do after registering, and how reporting suspicious activity protects not just regulators but the business itself. When companies understand that compliance safeguards their operations, reputation, and the wider economy, they start to see it not as a burden but as an enabler of safer, more sustainable growth.

For Full video of Panel discussion, visit:

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