Are anonymous or numbered accounts allowed under UAE AML law?
No. The UAE AML law expressly prohibits regulated entities from opening or maintaining accounts, or conducting any financial or commercial transactions, under anonymous, fictitious, alias or numbered names, and from providing any services to such accounts. This obligation applies to financial institutions, designated non-financial businesses and professions, and virtual asset service providers.
The prohibition supports the wider customer due diligence framework. If an entity cannot identify who it is truly dealing with, it cannot assess risk, monitor behaviour or file meaningful suspicious transaction reports. Anonymous and numbered accounts have historically been a route for concealing the true owner of funds, so removing them is a basic transparency safeguard aligned with international standards.
The law also targets anonymity in the virtual asset space. It is a criminal offence to promote, sell, provide services in, or deal with virtual assets characterised by total anonymity, or with unlicensed accounts or technologies that obstruct the authorities’ ability to trace a transaction or its parties. Compliance teams should therefore ensure every customer is properly identified and verified, and avoid products or channels designed to hide identity.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(c) — prohibits anonymous, fictitious, alias and numbered accounts.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.
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