When does an accountant or auditor become subject to AML obligations in the UAE?
An accountant or auditor becomes subject to UAE AML/CFT obligations once they provide relevant professional services to clients on an independent basis, such as auditing accounts, preparing financial statements, or acting in company formation and management activities. At that point they fall within the DNFBP definition and must apply the full range of preventive measures.
The obligation is triggered by the nature of the service rather than by the size of the client. Once inside the regime, the firm must carry out customer due diligence, keep records, monitor relationships, appoint a compliance officer, and report suspicions. In-house accountants employed by a single non-DNFBP business are generally outside the DNFBP scope, but external practitioners offering these services to third parties are clearly covered.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3 — defines the categories of DNFBPs, which capture independent accountants and auditors carrying out specified activities.
· Federal Decree-Law No. 10 of 2025, Article 2 — defines money laundering, the conduct these obligations are designed to prevent.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.