Methodology · Sources & Drafting
How the kits are built

How the kits are built.

The legal framework, the drafting process, the maintenance pledge, and the limits. Compliance work is only as good as its sources — so we name them.

The method

One method, four rulebooks.

Assay builds one kit per regulated sector — precious metals and real estate today, corporate service providers and accountants next. The method below is identical for every sector: the same drafting process, the same citation discipline, the same review gate. What changes is the rulebook — each sector's kit is drafted against its own instruments (the DPMSR regime for precious metals; the REAR regime for real estate) on top of the shared federal framework. About three-quarters of the framework is common; the quarter that differs is exactly the quarter an inspector tests.

Drafted against

The sources every document cites.

Every document in every kit is drafted against the current UAE AML/CFT framework, the supervising authority's published guidance, and the relevant international standards. Each document carries a Sources line listing the instruments it implements.

The shared federal framework
  • Federal Decree-Law No. 10 of 2025 FDL 10/2025 The primary AML/CFT/CPF law. In force 14 October 2025; replaced Law 20/2018.
  • Cabinet Resolution No. 134 of 2025 CR 134/2025 The executive regulations of FDL 10/2025. In force 14 December 2025.
  • Cabinet Resolution No. 71 of 2024 CR 71/2024 The unified DNFBP violations and administrative fines schedule (AED 50,000 to AED 1,000,000 per violation).
  • Cabinet Decision No. 109 of 2023 CD 109/2023 Beneficial-ownership procedures and the 25% control threshold. In force 6 November 2023; replaced Cabinet Decision No. 58 of 2020.
  • Cabinet Decision No. 74 of 2020 CD 74/2020 Sanctions implementation and the UAE Local Terrorist List.
  • FATF Recommendations 1, 10, 11, 22 The foundational standards on national risk, CDD, record-keeping and DNFBPs.
Precious metals
  • Ministerial Decree No. 68 of 2024 MD 68/2024 Due Diligence Regulations for Responsible Sourcing of Gold.
  • Ministry of Economy DPMS Supplemental Guidance Sector-specific operational guidance for Dealers in Precious Metals & Stones.
  • DMCC Guidance Note for Member Companies — AML/CFT DMCC's AML/CFT guidance for member companies, supplementing the federal framework with DMCC-specific operational expectations.
  • DMCC Rules for Risk-Based Due Diligence Supply-chain due-diligence requirements for DMCC members.
  • FATF Risk-Based Approach Guidance for DPMS International standard for risk-based AML in the precious metals sector.
  • OECD Due Diligence Guidance for Responsible Supply Chains The five-step framework for minerals from conflict-affected and high-risk areas.
  • Kimberley Process Certification Scheme For rough-diamond supply.
Real estate
  • Ministry of Economy Circular No. 05/2022 The Real Estate Activity Report (REAR) regime for brokers and agents.
  • UAE FIU goAML guides The Report Types guide and the REAR filing guide, the operational manuals for the sector's reporting duties.
  • CBUAE Guidance for LFIs servicing the real-estate sector The standard the buyer's and the brokerage's banks apply.
How it was written

Practitioners, not consultants.

Every document was drafted by practitioners with hands-on DMCC operational experience — the same people who deal with the regulator, the bank and the inspector in real life. Where the law is precise, we cite the article. Where the law leaves discretion, we apply the standard a competent professional would apply.

Each document was structured against real-world inspection requirements — DMCC's for precious metals, the Ministry of Economy and Tourism's for real estate — and cross-checked against what UAE banks actually request during DNFBP account opening. The Excel risk matrix carries working formulas, not display values. The training deck is ready to run as your next all-hands.

Every kit is reviewed for plain-English readability without sacrificing legal precision. Compliance documents that nobody reads are compliance documents nobody follows.

Before any sector's kit goes on sale, it passes a review by a UAE-qualified professional — the same gate, every sector.

12 months of updates

We keep the kits current.

Compliance frameworks move. Your purchase includes 12 months of free updates from delivery date. We monitor:

  • Ministry of Economy circulars and sector guidance — the DPMS rules and the REAR regime
  • DMCC member guidance updates and Practical Guidance revisions
  • Cabinet Resolution and Cabinet Decision amendments
  • FATF Grey- and Black-list changes
  • UAE Local Terrorist List updates and sanctions notifications

When any of these moves in a way that touches your kit, we reissue the affected documents and email the update to every active subscriber. Each document carries a versioning footer with the date last reviewed and the source it tracks.

Those updates also land in My Kit, the free account included with your kit: sign in to edit your firm profile, re-generate the kit with the latest documents, and track your recurring obligations on a compliance calendar that reminds you before each deadline. Sign in to My Kit →

Where the kit ends

Honest about the limits.

We sell a product, not a relationship. Here is what the kit does not do — read this before you buy.

  • Not legal advice. The kit reflects current UAE regulatory requirements. Final policies should be reviewed by a UAE-qualified compliance professional before adoption.
  • Not bespoke counsel. Higher-risk firms or unusual structures may need consultant input the kit can't replace. We tell you which firms.
  • Not a substitute for periodic external audit. The kit includes the audit-readiness checklist and the audit ToR template. The audit itself is a separate engagement.
  • Not a one-and-done. Compliance is an ongoing operational practice. The kit gives you the framework. You operate it.
Built · Sourced · Maintained

Built carefully. Sourced openly. Maintained.

Get the Starter Kit €899

Drafted against FDL 10/2025 · 12 months of free updates · 14-day money-back guarantee.

The Enforcement Brief

Subscribe to the Assay Enforcement Brief — quarterly analysis of UAE DNFBP fines and enforcement actions, free.