CBUAE Revokes Insurance Broker's Licence Over Persistent AML Non-Compliance

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CBUAE revokes another broker's licence for AML failures - the latest in a string of insurance sector enforcement actions since 2024.

The CBUAE has revoked an insurance broker's licence and struck the firm from its register for persistent failures in anti-money laundering compliance.
The action follows earlier administrative and financial sanctions imposed on five other insurance brokers in May 2025.
Licence revocation was based on a weak AML compliance framework and failure to meet regulatory obligations under UAE law.
Insurance brokers must implement customer due diligence, transaction monitoring, and suspicious transaction reporting through the goAML platform.
The Insurance Brokers' Regulation C 1/2024 makes AML/CFT readiness a core licensing condition for all CBUAE-supervised brokers.
Firms are advised to review their AML/CFT frameworks immediately, particularly around beneficial ownership verification and sanctions screening.

AML Enforcement Intensifies Across the UAE Insurance Sector

The Central Bank of the UAE (CBUAE) has revoked an insurance broker's licence and removed the firm from its official register. The enforcement action follows persistent non-compliance with anti-money laundering and combating the financing of terrorism (AML/CFT) requirements under federal law. It marks the latest in a series of regulatory actions targeting the insurance broking sector, signalling heightened expectations around customer due diligence and goAML suspicious transaction reporting.

This revocation builds on an enforcement trajectory that began in 2024 and has accelerated under the Insurance Brokers' Regulation C 1/2024, effective since February 2025. With CBUAE AML/CFT supervision intensifying across the industry and Federal Decree-Law No. 20 of 2018 providing the legal foundation for sanctions, firms that treat compliance as a peripheral function now face direct licensing consequences.

What the Enforcement Action Involves

The CBUAE determined that the broker maintained a weak AML compliance framework and had failed to meet its regulatory obligations. According to compliance analysis published by FinchInnovate, the regulator revoked the firm's licence and struck its name from the register. The decision effectively bars the broker from conducting any insurance brokerage activity in the UAE.

Under the Insurance Brokers' Regulation, no person may provide or engage in insurance brokerage within the UAE without a CBUAE licence. Removal from the register means insurers, reinsurers, and clients can no longer place business through the firm. Existing brokerage agreements must be unwound or transferred to a licensed intermediary.

In a statement accompanying an earlier enforcement action, the CBUAE said it works through its supervisory mandates to ensure all insurance professionals comply with UAE laws and standards. Licence revocation sits at the top of the regulator's enforcement toolkit. It is typically reserved for cases where ongoing supervision has failed to restore compliance.

Escalating Enforcement: The Sector Track Record Since 2024

The latest action is not an isolated case. In April 2025, the CBUAE revoked the licence of Dynamics Insurance Brokers under Article 22(2) of Insurance Authority Resolution No. 15 of 2013. That decision followed an examination revealing failures to comply with licensing terms and regulatory requirements.

One month later, the CBUAE imposed administrative and financial sanctions on five insurance brokers for AML and sanctions compliance violations. Two of the five received financial penalties under Article 14 of Federal Decree-Law No. 20 of 2018. The remaining three were issued formal warnings.

Date	Entity	Action Taken
Feb 2024	Smart and Secure Insurance Agent	Licence revoked, struck off register
Apr 2025	Dynamics Insurance Brokers	Licence revoked following examination
May 2025	Five unnamed insurance brokers	Administrative and financial sanctions
2026	Unnamed insurance broker	Licence revoked for weak AML framework

In February 2024, the CBUAE had already revoked the licence of Smart and Secure Insurance Agent for a weak compliance framework. Together, these actions bring the total to at least eight enforcement interventions against insurance brokers since early 2024. The pattern reflects a systematic supervisory campaign rather than isolated responses to individual complaints.

The Legal Framework Behind the Crackdown

The AML/CFT obligations applying to insurance brokers draw on several layers of legislation. Federal Decree-Law No. 20 of 2018 defines the core money laundering offences and establishes reporting obligations. Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 updated the framework, classifying life and investment-linked insurance as financial activity subject to full AML/CFT requirements.

The CBUAE's Guidance for the Insurance Sector, issued in October 2022, requires brokers to perform enterprise-wide risk assessments and implement proportionate customer due diligence. Brokers must screen against sanctions lists and file suspicious transaction reports through the goAML platform without delay. Failure to report a suspicious transaction is a federal crime under the AML/CFT law, regardless of the amount involved.

At the licensing stage, Article 2-6(m) of the Insurance Brokers' Regulation C 1/2024 requires applicants to demonstrate measures ensuring complete compliance with AML/CFT laws. This makes AML readiness a condition for initial licensing and an ongoing obligation. Brokers that allow their frameworks to deteriorate face the same escalation pathway that has already ended in licence cancellations for multiple firms.

Practical Steps for Insurance Brokers and Compliance Officers

Insurance brokers under CBUAE supervision should treat this enforcement action as a prompt for immediate review. Firms need to verify that their enterprise-wide AML risk assessments are current and aligned with the UAE's National Risk Assessment. Customer due diligence processes must cover beneficial ownership verification for corporate clients, enhanced checks for politically exposed persons, and ongoing monitoring of policy transactions. The CBUAE's tightening licensing rules make compliance a threshold condition for continued operation.

Specialist compliance training tailored to insurance-specific risks is equally important. The CBUAE's Best Practices guidance on role-based AML/CFT training expects brokers to deliver targeted programmes covering suspicious indicators for insurance products, goAML registration and filing procedures, and sanctions screening protocols. Firms should also ensure their compliance officers have adequate seniority, operational independence, and direct board-level access, as weak governance structures are a common finding in CBUAE examinations.

What Clients are Asking their Advisors

Can the CBUAE revoke an insurance broker's licence solely for AML compliance failures?

Yes. The Insurance Brokers' Regulation C 1/2024 makes AML/CFT compliance a licensing condition. If a broker fails to maintain the measures required under Article 2-6(m), the CBUAE can treat this as a breach of licensing terms and escalate to licence revocation. At least three brokers have lost their licences since 2024 following findings of non-compliance.

What AML reporting platform must UAE insurance brokers use?

All insurance brokers supervised by the CBUAE must register on the goAML platform operated by the UAE Financial Intelligence Unit. Suspicious transaction reports and suspicious activity reports must be filed through this system without delay. Registration is mandatory, and failure to report suspicious activity is a federal crime regardless of the transaction amount.

How does the CBUAE typically escalate enforcement against insurance brokers?

The CBUAE follows a graduated approach. Initial findings from supervisory examinations may result in formal warnings or modest administrative penalties. Persistent or serious deficiencies lead to financial fines under Article 14 of Federal Decree-Law No. 20 of 2018. Licence revocation and deregistration sit at the top of the enforcement toolkit and are reserved for cases where continued operation poses a risk to financial system integrity.

What happens to policyholders when their insurance broker loses its CBUAE licence?

When a broker is struck off the register, it can no longer intermediate insurance business. Existing policies placed through the broker remain valid with the underwriting insurer, but ongoing servicing, renewals, and claims support must transfer to a licensed intermediary. Clients should contact their insurer directly to confirm continuity of cover and arrange for a replacement broker if needed.