Which activities bring a UAE law firm within scope of AML regulations?
A UAE law firm is brought within scope of the AML regime when it prepares for or carries out specific transactions for clients. The main trigger activities are buying and selling real estate; managing client money, securities or other assets; managing bank, savings or securities accounts; organising contributions for the creation, operation or management of companies; and creating, operating or administering legal persons or arrangements, including buying and selling business entities.
General litigation and pure legal advice usually do not, by themselves, trigger the DNFBP obligations. It is the transactional and gatekeeper role, where the lawyer moves value or builds structures, that creates money laundering exposure. Once any trigger activity is performed, the firm must run its enterprise risk assessment, apply CDD, screen for sanctions, monitor the relationship and be ready to report suspicions.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 - imposes preventive obligations on DNFBPs performing in-scope activities.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - defines the categories of DNFBP activity that trigger compliance.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.