When do lawyers become subject to AML obligations in the UAE?
A lawyer or notary in the UAE becomes subject to AML obligations at the point they prepare, conduct or execute a financial transaction for a client in one of the defined categories. It is the nature of the transaction, not the client’s identity, that pulls the engagement into scope.
The defined categories are buying and selling real estate, managing a client’s money, managing bank, savings or securities accounts, organising contributions for the establishment, operation or management of companies, and establishing, operating or managing legal persons or arrangements, including buying or selling commercial entities. Once any of these is on the table, the firm must run customer due diligence before or during the transaction and treat the client as a business relationship for monitoring and record-keeping purposes.
Legal Reference (UAE):
· Cabinet Resolution 134/2025 (Executive Regulations), Article 3(4) — defines the trigger activities for lawyers and independent legal professionals.
· Federal Decree-Law 10/2025, Article 19(1)(b) — requires customer due diligence once obligations are engaged.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.