Must a UAE audit firm screen its own employees for fitness and propriety under AML rules?
Yes. Internal AML policies must include screening procedures that ensure high standards of fitness and propriety are applied when appointing employees. This is a control requirement in its own right, not simply good HR practice, and it applies to accounting and audit firms as DNFBPs.
The rationale is that professional service firms are a recognised gateway for professional money laundering. An employee with undisclosed connections to a client group, an adverse regulatory history in another jurisdiction, or an unexplained relationship with a beneficial owner represents a direct control failure. Screening at the point of hire should cover identity, qualification verification, employment history, regulatory and criminal record checks where permitted, and adverse media. For staff in compliance, client acceptance or partner roles, the checks should be deeper and repeated periodically rather than performed once at onboarding.
Screening records need to be retained and made available to the supervisor. Firms should also link the screening outcome to access rights, so that staff who have not cleared screening cannot open client files or approve onboarding decisions.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 21(4) — screening procedures to ensure high standards of fitness and propriety in appointing employees
· Cabinet Resolution No. 134 of 2025, Article 21(5) — periodic programmes and workshops to qualify compliance and other relevant staff
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.