Which accounting activities are covered by UAE AML/CFT obligations?
UAE AML law does not treat every accounting engagement as a regulated activity. Obligations are triggered when an accountant prepares, conducts, or executes transactions for a client in five specific areas. These are buying and selling real estate, managing client funds, managing bank, savings, or securities accounts, organising contributions for the creation or management of companies, and creating, operating, or managing legal persons or arrangements, including the sale or purchase of business entities.
When an engagement falls inside these covered activities, the accountant must apply the complete DNFBP obligation set. Routine bookkeeping or purely advisory work that does not involve executing these transactions may sit outside the trigger, but firms should assess each engagement carefully and document the reasoning, because the same client relationship can move in and out of scope over time.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3(4) - defines the five covered client activities for accountants.
· Federal Decree-Law No. 10 of 2025, Article 19 - preventive measures for covered persons.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.