What AML records must UAE law firms keep and for how long?
A law firm within scope must retain all records, documents and data relating to customer due diligence and to transactions for at least five years. The clock runs from the date the transaction is completed or from the end of the business relationship with the client, whichever applies.
The records must be organised so they can be reconstructed and made available to the competent authorities without delay on request, and they should be detailed enough to allow a transaction to be traced from start to finish. This covers identity and beneficial ownership documents, the risk assessment for the client, correspondence, and the basis for any decision to file or not file a suspicious transaction report. Keeping records only in scattered client files is not enough; the firm needs a system that lets it retrieve and produce them quickly.
Legal Reference (UAE):
· Cabinet Resolution 134/2025, Article 25 — requires retention of records for at least five years and their prompt availability.
· Federal Decree-Law 10/2025, Article 19(1)(f) — obliges DNFBPs to retain transaction records for the authorities.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.