Does a UAE law firm need to appoint an AML compliance officer?
Yes. A law firm within scope of the AML regime must put in place internal policies, controls and procedures approved by senior management, and appointing a competent AML compliance officer is a central part of meeting that duty. The compliance officer owns the day-to-day AML function: reviewing internal alerts, deciding on and filing suspicious transaction reports with the FIU, and acting as the firm’s point of contact with the supervisor.
The role should have enough seniority and independence to challenge fee-earners and, where necessary, decline or exit a matter. The officer is also responsible for staff training, keeping the risk assessment current, and arranging an independent review of the AML programme. In smaller firms the role may be combined with other duties, but the responsibilities and accountability remain the same.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(d) - requires internal policies, controls and procedures approved by senior management.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - sets the minimum requirements for the compliance function and officer.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.