Who must appoint an AML compliance officer in the UAE?
All financial institutions, DNFBPs and virtual asset service providers in the UAE must appoint a compliance officer at management level. This is a mandatory element of the internal anti-crime policies, controls and procedures that regulated entities must have approved by senior management.
The compliance officer must have independence in decision-making and appropriate competence and experience. The appointment cannot be a formality: the officer must be given the standing and access needed to monitor transactions, assess internal alerts, decide on reporting to the Financial Intelligence Unit, and report to senior management. For smaller businesses the role may sit with a suitably qualified senior individual, but the function itself, and the appointment, are required regardless of size. Failure to appoint a compliance officer is a supervisory breach that can attract administrative penalties.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 21(3) - internal controls must include appointment of a compliance officer at management level.
· Cabinet Resolution No. 134 of 2025, Article 22 - competence, independence and duties of the compliance officer.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.