Does organising contributions for the establishment of a company bring a UAE accountant within AML scope?
Yes. Independent accountants fall within the DNFBP definition when they prepare, conduct or execute financial transactions for a client in connection with a defined list of activities, and organising contributions for the establishment, operation or management of companies is one of them.
The full list also covers buying and selling real estate, managing funds owned by the customer, managing bank, savings or securities accounts, and establishing, operating or managing legal persons and legal arrangements, or the sale or purchase of commercial entities. The trigger is the nature of the activity, not the size of the fee, and it applies whether the accountant practises individually, as a partner, or as a professional within a firm.
This matters because many practices assume that only audit and bookkeeping work is in scope. It is the transactional and structuring work that brings the firm within the perimeter. A practice that helps a client assemble founder contributions, open the corporate bank account and appoint directors is carrying out several in-scope activities at once and must apply full customer due diligence, screen for sanctions and politically exposed persons, and maintain records for five years.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 3(4) — independent accountants are DNFBPs when preparing, conducting or executing listed financial transactions, including organising contributions for company establishment
· Cabinet Resolution No. 134 of 2025, Article 7 — cases in which CDD measures must be applied
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
AML compliance requirements for auditors and accountants in the UAE