Must a DNFBP appoint an AML compliance officer in the UAE?
Yes. Every DNFBP must appoint a compliance officer at management level as part of its internal AML policies and controls. The compliance officer, sometimes called the Money Laundering Reporting Officer, is responsible for overseeing the firm’s AML programme, reviewing internal alerts, deciding whether to notify the Financial Intelligence Unit, and acting as the point of contact with the supervisor.
The role must carry genuine authority, independence and resources, and the officer needs unrestricted access to the customer data, systems and management decisions relevant to managing crime risk. The compliance officer also reviews suspicious transaction reports raised internally, keeps records of the decisions taken, and reports to senior management. Smaller DNFBPs may outsource elements of the function, but responsibility for compliance remains with the business.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 21(3) requires the appointment of a compliance officer at management level.
· Cabinet Resolution No. 134 of 2025, Article 22 sets out the duties of the compliance officer.
For more details, consult the full text of Cabinet Resolution 134 of 2025 or seek guidance from your AML compliance officer.