Are sole practitioner accountants subject to AML registration requirements in the UAE?
Yes. Sole practitioner accountants in the UAE are subject to AML registration and compliance obligations in the same way as larger accounting firms, provided they engage in activities that trigger DNFBP status. The UAE’s Supplemental Guidance for Auditors explicitly states that its scope covers “audit professionals acting independently, whether as sole practitioners or as members or employees of firms or companies engaged primarily in the provision of audit-related services.”
Under Article 19 of Federal Decree-Law No. 10 of 2025, individual practitioners who prepare or execute qualifying financial transactions on behalf of clients, such as managing client funds, organising company formation, or managing bank accounts must register with the relevant supervisory authority, maintain a written AML/CFT policy, conduct customer due diligence, and report suspicious transactions to the FIU via goAML.
A sole practitioner who also acts as their own MLRO is permissible, but the individual must have sufficient competence to fulfil that role independently. The small size of a practice does not reduce the obligation. With the FATF’s onsite mutual evaluation of the UAE approaching in mid-2026, supervisory authorities are increasingly inspecting sole practitioners to verify their compliance status.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 19, AML obligations apply to all DNFBPs regardless of size or structure
- Ministry of Economy, Supplemental Guidance for Auditors (UAE DNFBP Guidelines), Confirms sole practitioners are within the scope of AML compliance obligations
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.