Are free zone law firms subject to UAE AML law?

UAE
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Yes. The federal AML framework applies across the UAE, and law firms operating in financial and non-financial free zones are covered when they carry on DNFBP activities. Ministerial Resolution No. 248 of 2025 expressly confirms that supervision of the legal profession extends to firms in free zones, not only those licensed onshore.

This means a free zone legal practice that handles real estate transactions, manages client funds or arranges company structures must register on goAML, apply customer due diligence, screen for sanctions, keep records and report suspicions in the same way as an onshore firm. Financial free zones such as the DIFC and ADGM operate their own regulators for entities within them, but the underlying expectation of an effective AML programme is consistent. Free zone status is not a shelter from AML obligations. Firms operating across both onshore and free zone jurisdictions should confirm which supervisor and portal apply to each entity, so that registration and reporting are handled through the correct channel.

Legal Reference (UAE):

  • Federal Decree-Law No. 10 of 2025, Article 20 - registration or enrolment requirement applies to all DNFBP activity.
  • Ministerial Resolution No. 248 of 2025 - confirms supervision extends to law firms in financial and non-financial free zones.

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

AML compliance requirements for law firms in UAE

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The AML law is federal legislation and applies throughout the UAE. Nothing in the Decree-Law or the Executive Regulations carves free zones out of the definition of DNFBPs, and a law firm carrying on the listed transactional activities is a DNFBP wherever in the country it is licensed.

What differs by location is the supervisory authority, not the obligation. The supervisory authority is whichever federal or local authority the legislation entrusts with supervising that category of business, and where none is designated, the competent authority responsible for granting approval to engage in the activity. A free zone firm should therefore identify which body supervises it for AML purposes, because that is the body that will inspect it and hold the Article 17 penalty powers.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 3(4): legal professionals as DNFBPs, with no free zone exclusion.

· Federal Decree-Law No. 10 of 2025, Article 1: the definition of Supervisory Authority including the licensing-authority fallback; Article 17: the penalties that authority may impose.

For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.

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