Is an accounting firm in the UAE criminally liable if a partner commits money laundering on its behalf?
Yes. A legal person is criminally liable where a money laundering, terrorist financing or proliferation financing offence is intentionally committed in its name or for its account. That liability sits alongside, and does not replace, the personal criminal liability of the individual who committed the act, and it is separate again from any administrative penalties the supervisor may impose.
The financial exposure for the firm is significant. A legal person whose representatives, directors or agents commit these offences on its behalf faces a fine of not less than AED 5,000,000. The court may also order the closure of premises and, in defined circumstances, the dissolution of the entity. Where the offence is committed, the person responsible for the actual management of the legal person may separately face imprisonment and a fine.
For partnerships and audit practices, the practical mitigation is governance: documented fit and proper screening of partners and staff, clear escalation channels that do not depend on a single individual, and an independent testing function that would detect a partner overriding controls. A firm that can show its controls were designed to prevent exactly this scenario is in a materially different position from one that cannot.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 4 — criminal liability of legal persons for offences committed in their name or for their account
· Federal Decree-Law No. 10 of 2025, Article 27 — fine of not less than AED 5,000,000, closure of premises and possible dissolution
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.