What AML training must a UAE accounting firm provide to its staff and how should it be documented?
The Compliance Officer is responsible for developing, implementing and documenting ongoing training programmes and training plans covering money laundering, terrorist financing and proliferation financing and the methods of combating them. The obligation is continuous, so a single induction session does not satisfy it.
Content should be tailored to what the firm actually does. Audit and assurance staff need to recognise red flags in client financial statements, unusual related party flows, round-sum consulting fees with no deliverable, and rapid changes in ownership. Client acceptance staff need to understand beneficial ownership, politically exposed persons and sanctions screening. Everyone needs to know the internal escalation route to the Compliance Officer and the absolute prohibition on tipping off. Where the firm serves higher risk sectors or jurisdictions, the training should reflect that exposure.
Documentation is what gets tested. Keep attendance records, the materials delivered, the date, the assessment results where testing is used, and evidence of follow-up for staff who did not attend. Training records fall within the general five-year retention requirement and should be producible on request.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 22(4) — Compliance Officer must develop, implement and document ongoing training programmes and plans
· Cabinet Resolution No. 134 of 2025, Article 25 — retention of records for not less than five years
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