Which specific client transactions bring UAE accountants within the scope of AML/CFT obligations?
Not every piece of accounting work triggers AML obligations in the UAE. Accountants become subject to the full range of AML/CFT duties, including customer due diligence and suspicious transaction reporting, only when they carry out, or prepare to carry out, certain defined activities on behalf of a client. In other cases, a risk-based approach may be taken by the entity.
Under Cabinet Resolution No. 134 of 2025, the triggering activities include: purchasing or selling real estate on behalf of a client, managing client funds or bank and securities accounts, organising contributions for company formation or management, and creating or operating legal persons or legal arrangements. General bookkeeping, audit work, or the preparation of financial statements does not, by itself, engage these obligations unless the accountant is also involved in the underlying transactions.
This scoping rule is important because it defines both when CDD must be conducted and when a Suspicious Transaction Report (STR) must be filed.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025 – defines the specific transactions that engage AML/CFT obligations for accountants and auditors
- Federal Decree-Law No. 10 of 2025, Article 15 – imposes CDD obligations on DNFBPs when engaging in designated transactions
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
AML Compliance Requirements for Auditors and Accountants in the UAE