Does a UAE law firm need to appoint an AML compliance officer?
Yes. A law firm within scope of the AML regime must appoint a compliance officer at management level, operating under the firm’s responsibility, with independence in decision-making and appropriate competence and experience. For law firms the appointment is also approved by the Ministry of Justice, generally during the goAML registration process.
The compliance officer’s duties include monitoring transactions for money laundering risk, reviewing and assessing suspicious transaction data and deciding whether to notify the Unit, keeping internal systems and procedures up to date, running staff training, and cooperating with the supervisor and the Unit. The role should have enough seniority and independence to act on a suspicion even where it is commercially inconvenient. Smaller firms can combine the function with another role, but the substance of independence and competence must still be met.
Legal Reference (UAE):
· Cabinet Resolution 134/2025, Article 22 — sets out the appointment and duties of the compliance officer.
· Cabinet Resolution 134/2025, Article 21(3) — requires anti-crime compliance management including a compliance officer at management level.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.