Is appointing a compliance officer mandatory under UAE AML law?
Yes. The Executive Regulations of the UAE AML law require financial institutions, designated non-financial businesses and professions, and virtual asset service providers to appoint a compliance officer at management level. The appointment is part of the broader obligation to establish internal policies, controls, and procedures approved by senior management to manage and mitigate the risks of money laundering and terrorism financing.
The compliance officer is responsible for overseeing the entity’s AML programme, including reviewing and reporting suspicious transactions to the Financial Intelligence Unit, ensuring customer due diligence and record-keeping obligations are met, and acting as the contact point with the supervisory authority. Supervisory authorities maintain an updated list of compliance officers of supervised entities and may require entities to obtain prior approval before appointing them. Firms should ensure the role carries sufficient seniority, independence, and resources to function effectively within their three lines of defence.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 21 — internal controls and appointment of a compliance officer.
· Cabinet Resolution No. 134 of 2025, Article 22 — duties of the compliance officer.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.