What AML records must a UAE law firm keep and for how long?
A UAE law firm acting as a DNFBP must retain all records, documents, data, and instruments relating to its transactions and client relationships for a period of not less than five years. The clock runs from the date the transaction is completed or from the end of the business relationship with the client, whichever is relevant.
Records to be kept include customer and beneficial owner identification data, due diligence findings, account files and business correspondence, the results of any analysis undertaken, and copies of suspicious transaction reports. The records must be sufficiently complete to allow reconstruction of individual transactions and must be made available promptly to the competent authorities on request. Where an investigation or reporting matter is ongoing, records may need to be kept beyond the five-year minimum. Good record-keeping is also the firm’s main evidence that its AML programme was applied.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 25 — requires retention of records for at least five years.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.