Do notaries public have AML obligations in the UAE?
Yes. Notaries public are included among the legal professionals treated as DNFBPs when they prepare for or carry out covered transactions for clients, such as dealings in real estate, the management of client assets, or the creation and management of legal persons and arrangements. In those situations a notary must apply customer due diligence, monitor the matter, and report suspicions to the Financial Intelligence Unit.
Notaries are supervised for AML purposes by the Ministry of Justice, alongside law firms and legal consultancies. Like other legal professionals, notaries may rely on the narrow professional secrecy exemption from reporting, but only for information obtained while ascertaining a client’s legal position or acting in judicial proceedings, not when performing a covered transactional service. Notaries should therefore build due diligence and record-keeping into their standard processes for the transactions they authenticate.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3 — includes notaries among covered legal professionals.
· Federal Decree-Law No. 10 of 2025, Article 18 — reporting duty and the professional secrecy exemption.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.