Are law firms subject to AML regulations in the UAE?
Yes. Law firms, legal consultancy offices and notaries are treated as Designated Non-Financial Businesses and Professions (DNFBPs) under UAE AML law, but only when they prepare, conduct or execute certain financial transactions for a client. The obligations are activity based rather than blanket, so they attach to specific work rather than to every legal service the firm provides.
The trigger activities include buying and selling real estate, managing a client’s funds, operating bank or securities accounts, organising contributions to establish or run companies, and creating or operating legal persons or arrangements. When a matter involves any of these, the firm must apply customer due diligence, monitor the relationship, keep records, screen against sanctions lists and report suspicious transactions. Ordinary litigation or advice that does not involve handling these transactions generally sits outside the scope.
Legal Reference (UAE):
· Cabinet Resolution 134/2025 (Executive Regulations), Article 3(4) — lists the specific activities that make lawyers, notaries and independent legal professionals DNFBPs.
· Federal Decree-Law 10/2025, Article 19 — sets out the core preventive obligations that then apply.
For more details, consult the full text of Federal Decree-Law 10/2025 or seek guidance from your AML compliance officer.