Which legal services trigger AML obligations for UAE law firms?
A law firm becomes subject to AML/CFT obligations when it prepares for or carries out certain transactions on behalf of a client. These triggering activities include 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 managing legal persons or arrangements.
When any of these services is provided, the firm must identify and verify the client and the beneficial owner, understand the purpose of the arrangement, monitor the relationship, and report suspicions. Purely advisory or litigation work that does not involve handling assets or structuring transactions generally falls outside these triggers. Firms offering a mix of services should map which engagements are covered so that due diligence is applied consistently to the right matters.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3 — lists the covered activities that classify legal professionals as DNFBPs.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 8 — sets when customer due diligence must be applied.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.