Are accountants and auditors considered DNFBPs under UAE AML law?
Yes. Independent accountants and auditors are expressly captured as Designated Non-Financial Businesses and Professions (DNFBPs) when they prepare, conduct, or execute certain financial transactions on behalf of their clients. This brings them within the full scope of the UAE AML/CFT framework, regardless of firm size.
Being a DNFBP means an accounting or audit practice must register on the FIU’s goAML portal, appoint a compliance officer, carry out customer due diligence, screen against sanctions lists, keep records, and file suspicious transaction reports. The obligation attaches to the nature of the activity performed, not merely the professional title, so sole practitioners and partners in larger firms are equally covered.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3(4) - lists independent accountants among DNFBPs for defined client activities.
· Federal Decree-Law No. 10 of 2025, Article 19 - sets out the preventive obligations of DNFBPs.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
Yes. Independent accountants and auditors are expressly captured as Designated Non-Financial Businesses and Professions (DNFBPs) when they prepare, conduct, or execute certain financial transactions on behalf of their clients. This brings them within the full scope of the UAE AML/CFT framework, regardless of firm size.
Being a DNFBP means an accounting or audit practice must register on the FIU’s goAML portal, appoint a compliance officer, carry out customer due diligence, screen against sanctions lists, keep records, and file suspicious transaction reports. The obligation attaches to the nature of the activity performed, not merely the professional title, so sole practitioners and partners in larger firms are equally covered.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3(4) - lists independent accountants among DNFBPs for defined client activities.
· Federal Decree-Law No. 10 of 2025, Article 19 - sets out the preventive obligations of DNFBPs.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.