What is the role of the MLRO in an accounting firm under UAE AML law?
The Money Laundering Reporting Officer (MLRO) in an accounting firm is the individual responsible for overseeing the firm’s AML/CFT compliance programme. Under Article 19 of Federal Decree-Law No. 10 of 2025, all DNFBPs, including accounting firms operating within the DNFBP scope must appoint a compliance officer with sufficient seniority and independence to fulfil this role effectively.
The MLRO’s key responsibilities include: receiving and reviewing internal suspicious activity reports from staff; deciding whether a report meets the threshold to be escalated externally to the FIU as an STR via goAML; ensuring all STRs are filed without delay; maintaining AML records and ensuring the firm’s policies are up to date; liaising with supervisory authorities during inspections; and delivering or overseeing AML training across the firm.
Critically, the MLRO must have direct access to senior management and the board, and must be able to act independently without undue influence from commercial pressures. In small or sole-practitioner firms, the principal may also serve as MLRO, but must demonstrate the competence and bandwidth to fulfil the role. The MLRO is the primary point of contact for the FIU and regulatory authorities, and personal accountability for AML compliance failures can extend to the MLRO individually under the UAE’s strengthened enforcement framework.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 19, Requirement to appoint a compliance officer (MLRO) for all DNFBPs
- Ministry of Economy, Supplemental Guidance for Auditors (UAE DNFBP Guidelines), Section 11.7.2, Governance framework including appointment and responsibilities of an AML/CFT Compliance Officer
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.