A UAE law firm must develop, implement and document ongoing training programmes for its employees on money laundering, terrorism financing and proliferation financing and the methods of combating them. Training is a core part of the compliance programme because policies only work if the people applying them understand the risks and their own reporting duties.
Responsibility for training sits with the compliance officer, who should tailor content to the firm’s risk profile and to specific roles, so that fee earners handling client money or company formation receive relevant, practical guidance. Training should cover how to recognise red flags, how customer due diligence works, the internal process for raising suspicions, the prohibition on tipping off, and sanctions screening. Sessions should be refreshed periodically and whenever the law, the firm’s risk assessment or its procedures change. The firm should keep attendance and content records so it can evidence to the supervisor that training actually took place and reached the right staff.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Article 22(4) - the compliance officer’s duty to run ongoing training programmes.
- Federal Decree-Law No. 10 of 2025, Article 19(1)(d) - internal policies, controls and procedures approved by senior management.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.