An independent accountant in the UAE is considered a "Designated Non-Financial Business or Profession" subject to Federal Decree-Law No. (10) of 2025 on Combating Money Laundering, the Financing of Terrorism, and the Financing of Illegal Organizations, when preparing, carrying out or executing financial transactions on behalf of clients in specific activities, such as buying and selling real estate, managing a client's money or bank accounts, or forming and managing companies. This triggers obligations regarding risk identification and customer due diligence.
When Is an Accountant Subject to the AML Provisions?
The law's Executive Regulation sets out when an accountant is considered a Designated Non-Financial Business or Profession, as this category includes "lawyers, notaries public, and other independent members of legal professions, and independent accountants, whether practicing individually, as partners, or as professionals in a firm practicing this profession, when preparing, carrying out or executing financial operations on behalf of their clients in relation to the following activities," namely:
- Buying and selling real estate.
- Managing money owned by the client.
- Managing bank accounts, savings accounts, or securities accounts.
- Organizing contributions for the creation, operation or management of companies.
- Creating, operating or managing legal persons or legal arrangements, or buying or selling business entities.
Unlike some other categories, such as commercial gaming operators or dealers in precious metals, the law does not set a minimum transaction value before an accountant is considered subject to these provisions; what matters is the nature of the activity itself, not its value.
Risk Identification and Due Diligence Obligations
The law requires every Designated Non-Financial Business or Profession, including independent accountants, to "identify, understand, manage and assess the risks of crime, in a manner commensurate with the nature and size of their business," and to document the risk identification and assessment processes and related information, retain and continuously update the relevant study, and provide it to the concerned authorities upon request.
The Exception for Legal Auditors During Judicial Representation
The law exempts, from a specific obligation, "lawyers, notaries public and other independent members of legal professions, and independent legal auditors, where obtaining information relating to those operations occurs in connection with assessing the client's legal position, defending or representing them before the courts, arbitration or mediation proceedings, or providing legal advice on a matter related to judicial proceedings."
Penalties for Money Laundering Under the Law
The law punishes the crime of money laundering with imprisonment for no less than one year and no more than ten years, and a fine of no less than "(100,000) one hundred thousand dirhams" and no more than "(5,000,000) five million dirhams," or the equivalent value of the related criminal property, whichever is greater. The penalty is increased to temporary imprisonment and a fine of up to "(10,000,000) ten million dirhams" in cases including abuse of one's job-related or professional influence. A legal person whose representatives or managers commit these crimes on its behalf is punished with a fine of no less than "(5,000,000) five million dirhams" and no more than "(100,000,000) one hundred million dirhams."
Legal References
- Federal Decree-Law No. (10) of 2025 on Combating Money Laundering, the Financing of Terrorism, and the Financing of Illegal Organizations — Article (26), Article (27).
- Cabinet Decision No. (134) of 2025 on the Executive Regulation of Federal Decree-Law No. (10) of 2025 — Article (3), Article (5), Article (18).
For questions about your specific situation, you can ask the UAE Tax & Legislation Helper on Helpers, or consult a licensed chartered accountant.