Must a DPMS in the UAE appoint a Money Laundering Reporting Officer?
Yes. Every DPMS that is brought within the scope of the UAE AML/CFT obligations. The MLRO must be a natural person resident in the UAE, with sufficient seniority and independence to discharge the role objectively, and must have direct access to senior management or the owner of the business.
The MLRO is responsible for designing and implementing the AML programme, ensuring goAML registration is current, reviewing internal escalations of suspicion, deciding whether to file STRs and DPMSRs, and serving as the contact point for the Ministry of Economy supervisor and the UAE FIU. The MLRO must also oversee customer due diligence, sanctions screening and the response to NAS alerts, manage the staff training programme, and prepare an annual compliance report for senior management. In smaller DPMS, the MLRO can perform these tasks personally; in larger entities, the MLRO heads a compliance team.
Personal accountability now attaches to the MLRO under FDL 10/2025 and Cabinet Resolution 71/2024, in addition to institutional liability for the firm. Failure of the MLRO to act on a clear suspicion, or to maintain the AML programme, can result in administrative penalties levied directly on the MLRO, removal from the role, and a bar on future appointment. DPMS must also notify the Ministry of Economy of the MLRO’s identity and any subsequent change.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Article 21 — appointment and duties of compliance officer
- Federal Decree-Law No. 10 of 2025, Article 16 — MLRO duty for DNFBPs
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.