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If you run an accounting or audit practice in the UAE, you are covered by the anti money laundering (AML) rules yourself. If you are a client, your accountant will ask you for identity and ownership documents because of those rules.
Who is covered by AML rules in the UAE?
Designated non-financial businesses and professions (DNFBPs) include auditors and accountants, company service providers, dealers in precious metals and stones, and real estate agents and brokers. The Ministry of Economy supervises them.
Source: UAE Government portal, Combatting money laundering, checked .
The current law
The AML law is now Federal Decree-Law No. 10 on AML, CFT and proliferation financing. It took effect on and repeals Federal Decree-Law 20. The executive regulations are in Cabinet Resolution No. 134, effective .
Source: Central Bank rulebook, Federal Decree-Law No. 10 and Cabinet Resolution No. 134, checked . This is a regulator site rather than the Ministry of Economy itself, so treat it as a secondary source and check the current text.
What is goAML registration and who needs it?
DNFBPs must register on the goAML portal so they can file suspicious transaction and suspicious activity reports. The Ministry of Economy has suspended businesses that did not register. One announcement was a three month suspension of 50 establishments.
Source: Ministry of Economy, registering companies in goAML, checked .
Penalty amounts under the new law are not covered on this page. Check the current law before you decide what a breach could cost.
What AML work do accounting firms do?
Firms that offer AML support usually cover some or all of this:
- Business risk assessment. Writing down which clients, services, countries and delivery channels carry more risk for your practice.
- Policies and procedures. A written AML manual that matches the risk assessment.
- Client due diligence. Identity checks, beneficial owner checks and source of funds questions at onboarding, repeated when something changes. See due diligence and the UBO register.
- Screening. Checking clients against sanctions lists.
- goAML set-up and reporting. Registering, training the compliance officer and drafting suspicious transaction reports.
- Training and testing. Staff training and an independent review of how well the procedures work.
- Record keeping. Holding client files so they can be produced when asked.
Some practices appoint a compliance officer in house. Others hire an outside firm to act as an AML adviser or run reviews. Both are common, and the choice depends on size and risk.
Why the rules reach accountants
Accountants and auditors handle the same information criminals try to hide: who owns a company, where its money comes from and how it moves. That is why the law treats a practice as a gatekeeper. The practice has to know its clients, spot unusual activity and report it through the proper channel, and it must not tip the client off.
For a small practice this does not need to be heavy. A short risk assessment, a standard onboarding checklist, a named compliance officer and a record of training can be enough to start. The Ministry of Economy sets what supervisors expect, so read its current guidance for DNFBPs and check that your procedures match it.
Questions to ask a firm
- What exactly is in the scope: manual, training, review, reporting, or all of it?
- Who does the work and what is their AML experience?
- Will you get a written report you can show a supervisor?
- Is the price fixed or by the hour, and what is excluded?
- How does the firm handle your client data?
If you want an external review of your books at the same time, see external audit. For regular bookkeeping help, see accounting services.
For clients of accounting firms
When your accountant asks for passports, trade licences, ownership charts or the source of a large payment, it is the AML rules at work. Refusing or delaying can stop the engagement. Have the documents ready.
This page is general information, not legal advice. DubaiAccountingFirms.com is an independent directory and not a regulator. To compare firms that offer AML support, send the form below.
