Do notaries have AML obligations in the UAE?
Yes. Notaries are named alongside lawyers and other independent legal professionals as DNFBPs under UAE AML law, and they carry the same activity based obligations. A notary comes into scope when preparing, conducting or executing a financial transaction for a client in one of the defined categories.
Those categories include real estate transfers, managing client funds or accounts, organising contributions to form or run companies, and creating or operating legal persons or arrangements. Because notarial work frequently touches property transfers and company formation, notaries often sit squarely within scope. When they do, they must apply customer due diligence, verify beneficial ownership, screen against sanctions lists, keep records for five years and report suspicious transactions through goAML. The Ministry of Justice supervises notaries public for these obligations.
Legal Reference (UAE):
· Cabinet Resolution 134/2025, Article 3(4) — includes notaries within the DNFBP definition for defined activities.
· Federal Decree-Law 10/2025, Article 18(1) — suspicious transaction reporting duty that applies to them.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.