How do UAE AML rules apply to lawyers forming companies or legal arrangements?
Forming or managing companies and legal arrangements is one of the specific activities that brings a lawyer within the AML/CFT framework as a DNFBP. When a lawyer creates, operates, or manages a legal person or arrangement, or organises contributions for its formation, the firm must apply full customer due diligence before providing the service.
That means identifying and verifying the client instructing the formation, identifying the natural persons who will be the beneficial owners of the new structure, understanding the purpose behind it, and screening the parties against sanctions lists. The firm should be alert to red flags such as unnecessarily complex ownership chains, reluctance to disclose the ultimate owner, or a structure with no clear commercial rationale, and must report a suspicious transaction where grounds exist. UAE transparency rules also require accurate beneficial ownership information to be obtained and retained for such entities.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3 — creating and managing legal persons or arrangements is a covered activity.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 9 — identify the customer and beneficial owner of the structure.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
Forming or managing companies and legal arrangements is one of the specific activities that brings a lawyer within the AML/CFT framework as a DNFBP. When a lawyer creates, operates, or manages a legal person or arrangement, or organises contributions for its formation, the firm must apply full customer due diligence before providing the service.
That means identifying and verifying the client instructing the formation, identifying the natural persons who will be the beneficial owners of the new structure, understanding the purpose behind it, and screening the parties against sanctions lists. The firm should be alert to red flags such as unnecessarily complex ownership chains, reluctance to disclose the ultimate owner, or a structure with no clear commercial rationale, and must report a suspicious transaction where grounds exist. UAE transparency rules also require accurate beneficial ownership information to be obtained and retained for such entities.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3 — creating and managing legal persons or arrangements is a covered activity.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 9 — identify the customer and beneficial owner of the structure.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.