Must a UAE law firm appoint an AML compliance officer?
Yes. Every DNFBP, including a law firm or legal consultancy, must appoint a dedicated AML/CFT compliance officer at management level who is approved by the relevant supervisory authority. The compliance officer leads the firm’s AML programme and acts as the point of contact with the supervisor and the Financial Intelligence Unit.
The role carries defined responsibilities. These include reviewing and reporting suspicious transactions to the Unit, maintaining the firm’s records of measures taken, keeping internal controls under periodic review as risk changes, running staff awareness programmes, and cooperating with the supervisor and the Unit by providing requested data and access to records. The officer should have sufficient seniority, independence, and resources to perform these duties, and smaller firms still need a designated individual even if the role is combined with others.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 22 — requires appointment of a compliance officer and sets out the role’s duties.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 21 — requires internal AML policies, controls, and procedures.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.