Are lawyers required to file suspicious transaction reports in the UAE?
Lawyers and other legal professionals are, as DNFBPs, generally subject to the suspicious transaction reporting duty when they carry out relevant financial activities for clients, such as managing money, real estate transactions or the creation of companies. However, the UAE law contains a narrow exemption. The reporting duty does not apply to lawyers, notaries, other legal professionals or independent legal auditors where the information relating to a transaction was obtained in circumstances subject to professional secrecy.
This exemption is limited to genuinely privileged information, typically obtained while ascertaining a client’s legal position or in the course of representing them in proceedings. It does not shield activity where the professional is used to facilitate money laundering, nor does it cover routine transactional services that fall outside legal privilege. Law firms should set clear internal criteria to distinguish privileged information from reportable activity, and should still maintain CDD and record-keeping.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18(2) - professional secrecy exemption from the reporting duty for legal professionals.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.