What enhanced due diligence must UAE accountants apply to high-risk clients?
When a UAE accountant identifies a higher risk of money laundering or terrorist financing, they must apply enhanced due diligence proportionate to that risk. This goes beyond standard checks and typically includes obtaining additional information on the client’s identity and occupation, on the beneficial owner, and on the source of funds and source of wealth, as well as understanding the purpose behind the relationship.
Enhanced measures are mandatory for clients connected to high-risk countries identified by the National Committee, for politically exposed persons, and for complex or unusual transactions with no clear economic purpose. For politically exposed persons the firm must also obtain senior management approval before establishing or continuing the relationship and must apply closer ongoing monitoring. The firm should document why a client was rated high risk and what additional steps were taken to manage that risk.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 16 — sets enhanced measures and senior management approval for politically exposed persons.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 23 — requires enhanced due diligence for dealings connected to high-risk countries.
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