What triggers customer due diligence for accountants in the UAE?
For UAE accountants and auditors, customer due diligence is triggered at the start of a business relationship, whenever there is a suspicion of money laundering or terrorist financing, and whenever there are doubts about the accuracy or adequacy of identification data already held. It is also required for occasional transactions above the prescribed threshold.
This means a firm cannot simply run identity checks once at onboarding and forget them. If a client’s circumstances change, if a transaction looks inconsistent with what the firm knows about the client, or if earlier documents appear unreliable, the firm must refresh its due diligence. The identity of both the customer and any beneficial owner must be verified using reliable, independent source documents before or during the establishment of the relationship.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 7 — lists the cases in which CDD measures must be applied.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 6 — requires verification of the customer and beneficial owner before or during the relationship.
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