Can a UAE accounting firm rely on another firm to perform customer due diligence?
Reliance on a third party is permitted, but on strict conditions and without any transfer of responsibility. The firm that relies on the introducer remains fully accountable for the adequacy of the due diligence. If the third party’s work turns out to be deficient, the relying firm is the one the supervisor will hold to account.
The conditions are practical. The relying firm must obtain the identification and verification data immediately, must be able to obtain copies of the underlying documents without delay on request, and must satisfy itself that the third party is regulated and supervised for AML purposes and applies standards at least equivalent to the UAE requirements. Reliance is not available where the third party is based in a jurisdiction identified as high risk, unless the relationship sits within a group applying group-wide programmes with adequately mitigated country risk.
For accounting practices this most often arises when a client is introduced by a corporate service provider or a member firm in another country. Getting a written reliance agreement in place, and actually testing that documents can be produced on demand, is the difference between a defensible arrangement and an unverified assumption.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 20 — conditions for reliance on a third party for CDD, including retained ultimate responsibility
· Cabinet Resolution No. 134 of 2025, Article 32 — group-wide programmes and information sharing
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.