What governance reporting line is required for the AML Compliance Officer in the UAE?
Under Cabinet Resolution No. 134 of 2025, the AML Compliance Officer must be a natural person of suitable seniority, experience and skill, appointed in writing, and granted a direct reporting line to the board of directors or to senior management. The role must be sufficiently independent to act without undue influence from commercial functions and must have unrestricted access to customer files, transaction data and management information necessary to discharge its duties.
The Compliance Officer is responsible for implementing the AML/CFT/CPF programme, reviewing customer risk assessments, escalating suspicious activity, filing STRs and SARs with the FIU, maintaining the entity’s record-keeping framework, and providing periodic reports to the board on programme effectiveness. Where the Compliance Officer is unable to perform their role independently because of resourcing, conflicts of interest or interference, the entity is exposed to enforcement action and the individual themselves may face personal liability.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, AML Compliance Officer article
- Federal Decree-Law No. 10 of 2025, governance provisions
For more details, consult the full text of Cabinet Resolution 134/2025