A client’s refusal to provide beneficial ownership information is one of the most significant red flags an auditor can encounter. Under Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, UAE auditors must obtain adequate CDD documentation before providing services, and a client who is unable or unwilling to provide this is, by definition, one whose CDD requirements cannot be met.
The first step is to make a formal written request to the client for the outstanding information, clearly stating the legal basis for the requirement and the deadline for a response. If the client continues to refuse or provides information that cannot be independently corroborated, the auditor must decline to commence or continue the engagement.
Declining an engagement on CDD grounds is not, by itself, a basis for filing an STR. However, where the refusal, combined with other circumstances surrounding the client or their activities, gives rise to a reasonable suspicion of money laundering or terrorist financing, the auditor is obliged to file an STR with the UAE FIU via the goAML portal. The STR must not be disclosed to the client.
Documentation of the entire process, including the original CDD request, the client’s response, the auditor’s assessment, and any STR decision, must be retained in accordance with the five-year record-keeping requirement.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025 — CDD requirements and obligation to decline services when CDD cannot be completed
- Federal Decree-Law No. 10 of 2025 — STR obligations where suspicion arises during a CDD process
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 UAE