In the 2003 FATF Recommendations these sectors sat in Recommendations 12, 16 and 24; today they are 22, 23 and 28. Two numbers now mark where a casino or a dealer comes under the rules: USD/EUR 3,000 for a casino customer's financial transactions and USD/EUR 15,000 for a dealer's cash transaction, counted across "several operations that appear to be linked" (FATF Recommendations, Interpretive Note to Recommendations 22 and 23, updated June 2026).
What are designated non-financial businesses and professions?
The FATF Glossary lists six groups: casinos, real estate agents, dealers in precious metals, dealers in precious stones, lawyers, notaries, other independent legal professionals and accountants, and trust and company service providers (TCSPs). Casinos include online and ship based casinos.
"Non-financial" means outside banks and other financial institutions, not outside money: the FATF Recommendations set duties for financial institutions first and apply them to DNFBPs through Recommendations 22 and 23. The Glossary also leaves out professionals employed inside other businesses or by government: an in house accountant at a retailer is not a DNFBP. A non profit organization (NPO) and a virtual asset service provider are not on the list either; FATF covers them under Recommendations 8 and 15.
Which businesses are DNFBPs under the FATF Recommendations?
Table 1. The FATF list of DNFBPs: what brings each one under AML rules, the threshold, and the main duty.
| Category | FATF trigger (R.22) | Threshold (Interpretive Note) | Main duties |
|---|---|---|---|
| Casinos | Customers' financial transactions at or above the threshold | USD/EUR 3,000 | Licensing, CDD, records, suspicious transaction reports |
| Real estate agents | Transactions for a client in buying and selling property | None set | CDD, records, suspicious transaction reports |
| Dealers in precious metals and stones | Any cash transaction with a customer at or above the threshold | USD/EUR 15,000, cash only | CDD and reports on those cash transactions |
| Lawyers, notaries and other legal professionals | Preparing for or carrying out listed transactions for a client | None set | CDD; reports when they carry out a financial transaction for the client |
| Accountants | The same listed transactions | None set | As for lawyers; FATF strongly encourages countries to extend reporting to audit work |
| TCSPs | Forming companies, acting as director, trustee or nominee shareholder, providing a registered office | None set | CDD and reports on those services |
A business counts as a DNFBP only while it carries out its trigger activity. For lawyers and accountants the listed transactions are property deals, client money and accounts, company contributions, legal persons and arrangements, and buying or selling a business.
Is every lawyer or accountant a DNFBP?
No. Picture two accountants (illustrative). One files tax returns for local shops. The other holds a client's money and pays it out to buy an apartment. Under Recommendation 22(d), only the second prepares for or carries out a listed transaction for a client, so only the second sits inside the FATF definition.
The duty follows the activity, not the job title: check what the professional does for each client before deciding whether a DNFBP duty applies. The EU draws the line wider. The AML Regulation names auditors, external accountants and tax advisors as obliged entities outright (Regulation (EU) 2024/1624, Article 3), so in the EU the first accountant is covered too.
What are the AML and CFT obligations of DNFBPs?
The key obligations and requirements for DNFBPs come from two recommendations, and they cover terrorist financing (CFT) as well as money laundering. Recommendation 22 applies customer due diligence (CDD), record keeping for at least five years, the politically exposed person checks, new technology risks and the rules on relying on third parties. Recommendation 23 adds internal controls, enhanced measures for higher risk countries, reporting and the ban on tipping off.
Enhanced due diligence (EDD) applies where the risk is higher, including politically exposed persons and their families. When a DNFBP suspects criminal proceeds in a covered activity, it files a suspicious transaction report, the equivalent of a suspicious activity report, with its financial intelligence unit.
Most of these duties start with knowing the client and the owner behind it. complead, formerly Sanction Scanner, supports that step with customer risk assessment and KYC that scores each client on weightings the firm defines, shows the factors behind every rating and starts EDD when a score reaches the level the firm sets.
Why are DNFBPs considered high risk, sector by sector?
The sector specific risks come from what each business handles:
- Casinos. Cash goes in as chips and can leave as a payout by transfer, which is why casinos and gaming operators need player due diligence.
- Dealers in precious metals and stones. Gold and diamonds carry high value in a small, portable form and can change hands for cash.
- Real estate agents. One sale can move a large sum in a single step.
- Lawyers, accountants and TCSPs. They form the companies and trusts that can hide the real owner, which makes them gatekeepers to the financial system.
What compliance challenges and AML trends do DNFBPs face?
The compliance challenges faced by DNFBPs often come down to size and fragmentation: small firms without a compliance team, and a different supervisor per sector. Recommendation 28 asks for licensed, supervised casinos and, for the rest, a supervisor or a professional body. The key AML trends of 2025 and 2026 concern who supervises and how far the list reaches:
- 21 October 2025, UK. The government decided that the Financial Conduct Authority will take over AML supervision of legal, accountancy and trust and company service providers; 22 professional body supervisors oversee the legal and accountancy sectors today. Its 18 June 2026 response sets out the FCA's duties, powers and accountability.
- 19 March 2026, US. A federal court in Texas vacated FinCEN's Residential Real Estate Rule; FinCEN has appealed, and no reports are due meanwhile. US rules still cover dealers that bought and sold over $50,000 in covered goods in the prior year (31 CFR 1027.100).
- 10 July 2027 and 10 July 2029, EU. The AML Regulation applies from 2027, and to football agents and professional football clubs from 2029.
FATF's list still names six groups; by July 2029 the EU's runs to football clubs. For any firm outside banking, the question is whether its own activity has joined the list.
Related terms
- Enhanced due diligence (EDD). Extra checks where the risk is higher.
- Suspicious activity report. Filed with the financial intelligence unit when a firm suspects crime.
- AML compliance officer. The person who answers for the firm's AML program.
- Front company. A real business used to mix criminal money with clean revenue.
- Regulation. A binding rule made under powers a law gives.
How this entry was checked
Written by Sinan Tekin, Regional Sales Manager, and reviewed by Dilara Diker, Head of Compliance; last reviewed 26 October 2026. Sources checked on 26 October 2026: the FATF Recommendations (June 2026) with the Interpretive Note to Recommendations 22 and 23 and the Glossary, Regulation (EU) 2024/1624, HM Treasury's supervision reform consultations (21 October 2025 outcome, 18 June 2026 response), FinCEN's Residential Real Estate Rule page and 31 CFR Part 1027. The category list and thresholds follow the FATF text.
