# What should a UAE law firm do if it cannot complete customer due diligence? **URL:** \ **Category:** UAE\ **Tags:** str, dnfbps, cdd\ **Created:** [July 30, 2026, 9:26am UTC](https://www.amlfaqs.com/t/what-should-a-uae-law-firm-do-if-it-cannot-complete-customer-due-diligence/1297 "2026-07-30T09:26:44Z")\ **Posts on this page:** 4\ **Page:** 1
**Author:** ![Monika](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/monika/32/200_2.png) [@Monika](https://www.amlfaqs.com/u/Monika)\ **Post date:** [July 30, 2026, 9:26am UTC](https://www.amlfaqs.com/t/what-should-a-uae-law-firm-do-if-it-cannot-complete-customer-due-diligence/1297/1 "2026-07-30T09:26:44Z")
If a law firm is unable to complete customer due diligence, it must not open the account, establish the business relationship or carry out the transaction, and where a relationship already exists it should consider terminating it. Incomplete due diligence means the firm cannot properly understand who it is dealing with, which is exactly the situation the rules are designed to prevent. Where the inability to verify identity or beneficial ownership arises alongside grounds for suspicion, the firm must also consider filing a suspicious transaction report to the Financial Intelligence Unit. The firm should avoid tipping off the client while it assesses the position, and route the decision through the compliance officer. There is a limited ability to defer completing verification in defined low-risk situations, but that is an exception rather than the norm and must be managed carefully. Walking away from a client who will not provide required information is a legitimate and often necessary compliance outcome. **Legal Reference (UAE):** - [Cabinet Resolution No. 134 of 2025](https://rulebook.centralbank.ae/en/rulebook/cabinet-resolution-no-134-2025-regarding-executive-regulations-federal-decree-law-no-10), Article 14 - action required where CDD cannot be completed, including ongoing monitoring and cessation. - [Federal Decree-Law No. 10 of 2025](https://rulebook.centralbank.ae/en/rulebook/federal-decree-law-no-10-2025-regarding-anti-money-laundering-and-combating-financing), Article 18 - duty to report suspicious transactions where suspicion arises. _For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer._ [AML compliance guide for law firms in UAE](https://amluae.com/aml-compliance-guide-for-law-firms-in-uae/) ---
**Author:** ![pathik](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/pathik/32/5_2.png) [@pathik](https://www.amlfaqs.com/u/pathik)\ **Post date:** [July 30, 2026, 9:26am UTC](https://www.amlfaqs.com/t/what-should-a-uae-law-firm-do-if-it-cannot-complete-customer-due-diligence/1297/2 "2026-07-30T09:26:45Z")
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**Author:** ![Monika](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/monika/32/200_2.png) [@Monika](https://www.amlfaqs.com/u/Monika)\ **Post date:** [September 10, 2026, 12:32am UTC](https://www.amlfaqs.com/t/what-should-a-uae-law-firm-do-if-it-cannot-complete-customer-due-diligence/1297/3 "2026-09-10T00:32:17Z")
It must not proceed. Financial institutions, DNFBPs and virtual asset service providers are prohibited from establishing or continuing a business relationship, or executing a transaction, where they are unable to apply customer due diligence measures, and must consider submitting a suspicious transaction report to the Financial Intelligence Unit whenever necessary. There is a separate route where the firm suspects a crime. If it has reasonable grounds to believe that applying customer due diligence measures may alert the client, it may refrain from applying them, but it must then submit a suspicious transaction report stating the reasons for not applying those measures. The choice is therefore between completing due diligence, declining the relationship, or reporting: it is not between completing due diligence and proceeding anyway. **Legal Reference (UAE):** · [Cabinet Resolution No. 134 of 2025](https://rulebook.centralbank.ae/en/rulebook/cabinet-resolution-no-134-2025-regarding-executive-regulations-federal-decree-law-no-10), Article 14(1): prohibition on establishing or continuing a relationship or executing a transaction where CDD cannot be applied. · [Cabinet Resolution No. 134 of 2025](https://rulebook.centralbank.ae/en/rulebook/cabinet-resolution-no-134-2025-regarding-executive-regulations-federal-decree-law-no-10), Article 14(2): refraining from CDD where it would tip off, subject to filing a report stating the reasons. _Where the position is finely balanced, document your reasoning and raise it with your compliance officer._ [KYC and CDD services](https://amluae.com/kyc-and-cdd-services/) ---
**Author:** ![Monika](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/monika/32/200_2.png) [@Monika](https://www.amlfaqs.com/u/Monika)\ **Post date:** [October 5, 2026, 11:14am UTC](https://www.amlfaqs.com/t/what-should-a-uae-law-firm-do-if-it-cannot-complete-customer-due-diligence/1297/4 "2026-10-05T11:14:55Z")