Which accountants are exempt from STR reporting obligations under UAE AML law?
A narrow category of independent legal auditors in the UAE benefits from an exemption from the standard Suspicious Transaction Report (STR) filing obligation under Article 18(2) of Federal Decree-Law No. 10 of 2025. This exemption applies specifically where the information relating to the suspicious transaction was obtained under circumstances subjecting the professional to professional secrecy — in other words, where reporting would breach legally protected attorney-client or equivalent privilege.
This exemption is narrowly drawn and applies to lawyers, notaries, other legal professionals, and independent legal auditors only when the information was received in a legally privileged context. It does not apply to general accountants or auditors who receive information in the ordinary course of commercial client work, as that information is not typically protected by professional secrecy.
For the vast majority of accounting and auditing professionals, no exemption applies. When a suspicion arises during the course of carrying out services that fall within the DNFBP scope, such as managing client funds, processing real estate transactions, or organising company formation, the STR obligation is absolute. An accountant cannot decline to report because the client is also a legal entity or because of concerns about the client relationship.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 18(2), Professional secrecy exemption applies only to lawyers, notaries, legal professionals, and independent legal auditors in specific circumstances
- Ministry of Economy, Supplemental Guidance for Auditors (UAE DNFBP Guidelines), Section 11.7.1, Scope and limitations of the professional secrecy exemption
For more details, consult the full text of Federal Decree-Law No. 10 of 2025