What AML obligations apply to independent accountants in the UAE under Federal Decree-Law No. 10 of 2025?

UAE
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What AML obligations apply to independent accountants in the UAE under Federal Decree-Law No. 10 of 2025?

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Independent accountants in the UAE are classified as Designated Non-Financial Businesses and Professions (DNFBPs) under Federal Decree-Law No. 10 of 2025 when they prepare, conduct, or execute financial transactions on behalf of clients. These transactions include buying or selling real estate, managing customer funds, managing bank or securities accounts, organising contributions for company formation, and establishing or managing legal persons or legal arrangements.

Once these activities are triggered, accountants must fulfil a full suite of AML/CFT obligations under Article 19 of the Decree-Law. These include identifying and assessing money laundering and terrorism financing (ML/TF) risks, implementing risk-based Customer Due Diligence (CDD), establishing and maintaining written internal AML policies approved by senior management, reporting Suspicious Transactions to the Financial Intelligence Unit (FIU) without delay via the goAML portal, and retaining all relevant records for a minimum of five years.

Accountants must also appoint a Money Laundering Reporting Officer (MLRO) with sufficient seniority and independence to oversee the firm’s AML compliance programme. Failure to comply with these obligations can result in administrative penalties ranging from AED 10,000 to AED 5,000,000 per violation under Article 17 of the Decree-Law, in addition to potential criminal liability.

Legal Reference (UAE):

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

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