What AML internal policies must a UAE law firm implement?
A law firm must put in place documented internal anti-crime policies, controls, and procedures, approved by senior management, that enable it to manage and mitigate the risks identified in its risk assessment. These must be applied across the firm, kept under continuous review, and updated as risks change.
At a minimum the framework should cover customer due diligence and enhanced due diligence, ongoing transaction monitoring, sanctions and PEP screening, the process for identifying and reporting suspicious transactions, record-keeping, and the appointment and duties of the compliance officer. It should also include employee screening to ensure fitness and propriety, and periodic training programmes so staff can recognise and respond to money laundering and terrorist financing risks. The policies must be proportionate to the size and nature of the firm and be capable of demonstrating compliance to the Ministry of Justice on inspection.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 21 — requires internal AML policies, controls, and procedures approved by senior management.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 22 — compliance officer, employee screening, and training.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.