What should a UAE accountant do if customer due diligence cannot be completed?
If an accountant cannot complete the required customer due diligence, they are prohibited from establishing or continuing the business relationship or executing the transaction. The firm must not proceed on incomplete identification of the client or the beneficial owner.
In that situation the firm should consider whether the failure itself gives grounds for suspicion and, where appropriate, submit a suspicious transaction report to the FIU through goAML. The regulations do allow a firm to refrain from pursuing further due diligence where continuing would tip off the client, provided a report is filed instead. Every decision to decline or exit a relationship on these grounds should be documented so the reasoning can be shown to the supervisor.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 14 - prohibition on proceeding where CDD cannot be applied, and consideration of an STR.
· Federal Decree-Law No. 10 of 2025, Article 18 - duty to report suspicion to the FIU.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.