What activities trigger AML compliance obligations for an independent accountant in the UAE?

UAE
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What activities trigger AML compliance obligations for an independent accountant in the UAE?

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AML compliance obligations for an independent accountant in the UAE are triggered by specific types of client-facing activities. Under Cabinet Resolution No. 134 of 2025, an independent accountant becomes a DNFBP, and subject to full AML obligations, when they prepare, conduct, or execute financial transactions on behalf of clients in connection with: buying or selling real estate; managing customer funds; managing bank, savings, or securities accounts; organising contributions for the establishment or management of companies; and establishing, operating, or managing legal persons or legal arrangements, or buying and selling commercial entities.

Accounting firms should conduct an internal assessment of their service lines to determine which activities trigger these obligations, and ensure those services are covered by a compliant AML programme.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.

AML Compliance Requirements for Auditors and Accountants in the UAE