Does a UAE accounting firm need to appoint an AML compliance officer?
Yes. Every UAE accounting or audit firm operating as a DNFBP must appoint a compliance officer at management level who has independence in decision-making and appropriate competence and experience. This individual, often called the Money Laundering Reporting Officer, is the anchor of the firm’s AML programme.
The compliance officer’s duties include monitoring transactions for links to crime, reviewing and assessing suspicious transaction data, deciding whether to file reports with the Financial Intelligence Unit, maintaining records, and ensuring staff receive AML training. The role must carry enough seniority and authority to act on suspicions without needing sign-off from the very people whose transactions might be in question. In a small practice the partner responsible must still ensure the function is real and adequately resourced, not merely a name on an organisation chart.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 22 — requires appointment of an independent compliance officer at management level and sets out the duties of the role.
· Federal Decree-Law No. 10 of 2025, Article 16 — establishes supervisory oversight of these compliance obligations.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.