Law firms operating in the UAE are subject to anti-money laundering and counter-terrorism financing (AML/CTF) obligations when conducting activities classified as Designated Non-Financial Business or Profession (DNFBP) services — such as assisting with company formation, managing client funds, or participating in certain financial transactions.
The UAE Ministry of Justice Guide on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organizations states on page 15:
“The Law Firm should prepare bi-annual reports and present them to the Senior Management, with copy to the Anti-Money Laundering and Combating Terrorism Financing Department at the Ministry of Justice, including comments and decisions of the Senior Management.”
Since the publication of that guidance, the UAE AML regulatory framework and supervisory infrastructure have been significantly updated and digitised. The practical implementation of this reporting requirement must therefore be assessed in light of the current regulatory environ...