What customer due diligence must UAE lawyers perform?
When a lawyer or law firm is within scope, it must identify the client and verify identity using reliable, independent source documents, identify and verify the beneficial owner behind the client, understand the purpose and intended nature of the business relationship, and monitor the relationship and transactions on an ongoing basis.
Due diligence is risk based, so the depth of the checks scales with the risk presented by the client, the service and the jurisdictions involved. For higher-risk clients the firm applies enhanced measures; for genuinely low-risk situations, simplified measures may be justified and documented. Due diligence should be completed before or during the transaction, and the firm must keep the information current rather than treating onboarding as a one-off. Where the firm cannot complete due diligence, it should not proceed with the transaction and should consider whether a suspicious transaction report is warranted.
Legal Reference (UAE):
· Federal Decree-Law 10/2025, Article 19(1)(b) — requires customer due diligence and ongoing monitoring.
· Cabinet Resolution 134/2025, Article 4 — details the customer due diligence measures and their scope.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.