Are lawyers considered DNFBPs under UAE AML law?
Yes. Independent legal professionals, including lawyers, legal consultancy offices and notaries, are treated as Designated Non-Financial Businesses and Professions (DNFBPs) when they prepare, carry out or execute certain transactions for their clients. That designation pulls them into the full preventive framework of the UAE AML law rather than leaving compliance to financial institutions alone.
In practice, being a DNFBP means a law firm must assess its money laundering, terrorist financing and proliferation financing risk, run customer due diligence, keep records, screen against sanctions lists and report suspicious transactions. The size of the firm does not change the obligation. A sole practitioner and a large practice carry the same duties once they perform in-scope activities such as buying or selling real estate, managing client money, or forming and administering companies on a client’s behalf.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 - sets the core preventive obligations (risk assessment, CDD, internal controls, record keeping and sanctions measures) that apply to DNFBPs, including legal professionals.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - specifies how these obligations apply to DNFBPs in practice.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.