Does professional secrecy exempt UAE lawyers from AML reporting?
Only in a defined and limited situation. UAE AML law exempts lawyers, notaries, other independent legal professionals and independent statutory auditors from the suspicious transaction reporting duty where the information was obtained in the course of assessing a client’s legal position, defending or representing the client before courts, or in arbitration or mediation, or when providing a legal opinion about judicial proceedings, including advice on initiating or avoiding them.
The exemption is tied to genuine legal advice and litigation privilege, not to transactional work. If a lawyer is handling a property purchase, moving client funds or setting up a corporate structure, that is DNFBP activity and the reporting duty applies in full. Trying to shelter transactional conduct behind professional secrecy will not hold. Firms should document why a matter does or does not fall within the exemption so the position can be defended on inspection.
Legal Reference (UAE):
· Cabinet Resolution 134/2025, Article 18(2) — sets out the professional secrecy exemption and its boundaries.
· Federal Decree-Law 10/2025, Article 18(2) — confirms the exemption at primary law level.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.