Can a UAE law firm rely on a third party for customer due diligence?
In limited circumstances a law firm may rely on a qualifying third party to perform elements of customer due diligence, but the firm always keeps ultimate responsibility for meeting its obligations. Reliance does not transfer accountability, so if the underlying due diligence is inadequate, the relying firm is answerable to its supervisor.
Where reliance is used, the firm must obtain the necessary identification information immediately, satisfy itself that the third party is regulated and supervised for AML purposes and applies equivalent standards, and ensure it can obtain copies of the underlying due diligence documents without delay on request. Reliance is generally not appropriate for parties based in high-risk jurisdictions. Because of these conditions, many firms prefer to conduct their own due diligence for higher-risk matters and reserve reliance for lower-risk, well-documented situations.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 — the firm retains responsibility for its risk-based obligations.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.