A detailed guide of AML compliance requirements for auditors and accountants in the UAE

A detailed guide of AML compliance requirements for auditors and accountants in the UAE

The profession of auditors and accountants is not an easy thing. They have access to the financial records and activities of their clients. This accessibility to financial records increases their vulnerability to money laundering. The involvement of their clients in money laundering activities also increases their exposure.

So, they must be extra vigilant to the risks of money laundering and terrorism financing. In this article, we list down the red flags of money laundering that auditors and accountants must be aware of. We also mention the important AML requirements that they must fulfil to remain in compliance with UAE’s AML regulations.

Key aspects that make auditors and accountants vulnerable to money laundering and financial crime

Some of aspects of the profession of auditors and accountants make them vulnerable to financial crimes. They must be aware of these factors to save themselves from becoming a victim of money laundering and terrorism financing. These factors include:

AML regulation for auditors and accountants in UAE

Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations is the primary law for AML in UAE. The Cabinet Decision No. 10 of 2019 concerning the Implementing Regulation of this Decree-Law makes accountants and auditors subject to the AML law. This means that the AML law applies to all auditors and accountants in UAE.

The Cabinet Decision provides a list of Designated Non-Financial Businesses and Professions (DNFBPs). AML regulations apply to these DNFBPs that include auditors and accountants. Given the nature of their profession and the content of their duties, accountants and auditors must comply with AML requirements as stated in the regulations for DNFBPs.
Their exposure to money laundering and financial crime activities is high because of the nature of their profession. They are responsible for financial management, examination of financial records and accounts, and assessment of governance structure and control procedures. These activities are the reason why illicit organizations or individuals exploit or bribe auditors and accountants to launder money.
The Ministry of Economy of UAE provides a Supplemental Guidance for auditors and accountants. It mentions in detail the AML/CFT obligations for both of these professions. These obligations include risk identification, customer due diligence, identification and reporting of suspicious transactions, and internal control and governance frameworks.

Complying with AML and CFT

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AML/CFT compliance requirements for auditors and accountants in UAE

Auditors and accountants must comply with the following requirements under the AML regulations of UAE:

Understand possible ML/FT risk exposure

You must have a detailed understanding of how your accounting and auditing business can be exposed to ML and FT risks. This requires an assessment at both the enterprise level and customer level. For this:

  • You must adopt a risk-based approach to identify risks in your business transactions. These risks may be of different types based on business nature, type of service, the operational environment, and other factors. Accordingly, you must adopt risk mitigation measures. 
  • You must be aware of the source of ML/FT risks and the phase in which the money laundering risk is high. You must know the client who is exposing you to such money laundering risks. 
  • You must know the transactions of clients that are making you vulnerable to financial crimes – valuation of certain types of assets or liabilities, approval of changes in a company’s capital structure, approval of company restructuring option, use of reserve account, approval of write-off of uncollected debt, payments from clients that are proceeds of financial crimes, or any other. 
  • You must consider different types of risks to your business due to money laundering. These risks include customer risk, geographic risk, transaction risk, channel risk, or any other. You must be able to identify each type and strategize for their elimination. 
  • You must conduct a risk assessment to understand the impact of these risks on your business. You must also analyze it in depth, document it, and update it as and when the changes occur. 
You must conduct a similar assessment of ML/FT risks on your client’s business. You must identify potential risks, adopt a risk-based approach, and document the methodologies adopted. Also, based on the client’s type and nature of business, you must appoint Compliance Officer and relevant team members to facilitate compliance with AML regulations.

Put in place internal policies, controls, and procedures

Auditors and accountants must implement necessary measures to manage and mitigate the ML/FT risks. One of the key measures is the implementation of strong and effective internal policies, controls, and procedures. You must assess these policies for effectiveness and update them accordingly as and when the need arises. 

These policies must relate to customer due diligence and suspicious transaction reporting. It must also include requirements for governance and record-keeping. Overall, such procedures must ensure management and mitigation of risks. 

Auditors and accountants must apply the same for their client’s businesses as well. They must check whether the client has implemented relevant internal policies and control measures related to AML/CFT. They must ensure that these policies and procedures are in alignment with the risk appetite of the client.

Implement customer due diligence measures

Auditors and accountants must apply the necessary customer due diligence (CDD) measures based on the category and profiling of the ML/FT risk. If there is any change in the risk category, they must be ready to update the due diligence measures as well. You must apply these measures during or before the transaction happens or the business relationship starts.
You need to apply similar CDD measures for your clients as well. These due diligence measures include the following:

Seek expert assistance of AML UAE

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Report suspicious transactions to Financial Intelligence Unit (FIU)

Auditors and accountants must report any kind of suspicious transactions to the Financial Intelligence Unit as and when they suspect it. You must add all the relevant information for the suspected transaction and keep it updated. You must be extra vigilant to identify any suspicion in any transaction or customer.
Some of the indicators for suspicious transactions in their own business or client’s business include:
  • Unnecessary complex transactions whose purpose or beneficial owner is not known
  • Transactions that are inconsistent with the customer’s risk profiling
  • Large transactions (relatively large to a customer’s income or turnover) that are unusual for that client
  • Large deposits or withdrawals inconsistent with customer’s business nature
  • Unexplained changes in the ownership of entities or unnecessary involvement of a third party
  • Transactions involving high-risk countries or third parties with no relationship with customers
  • Unclear or dubious sourcing of funds for a transaction
  • Refusal of customers to provide relevant information or proofs required for due diligence measures

Ongoing monitoring of their and clients’ activities

Auditors and accountants must be vigilant of their clients’ activities and transactions. They must protect their business transactions and their clients’ from possible misuse by terrorists or criminals. So, you must check the client’s business and transactions often to be sure of no involvement of financial crime.
You must do continuous monitoring of the following activities of your client’s business:
  • You must check for any unexpected changes, amendments, or transfers that are unusual to your client’s routine transactions. 
  • You must keep a check on any changes in ownership, capital contributions, dividend payments, powers of attorney, or any other transaction that changes the control of the client’s business.
  • You must monitor any unusual transaction, which does not align with the client’s expected business activity. This may include funds transfers or financial transactions, or any other transaction that does not give the correct source of financing. 
  • An important consideration for auditors and accountants must be to check the source of the payments received from clients. You must ensure that the payments come from known sources and not from any unknown foreign accounts or third parties. The mode of payment must be such that it does not hide the origin of funds and must be the usual mode used by the client. 

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Auditors must understand the vulnerability of their professional activities to money laundering risks. With that understanding, they must implement the above measures to comply with UAE’s AML/CFT regulations. These measures ensure that they themselves and their clients are not exposed to money laundering or terrorism financing activities.

To plan and implement any of these measures, you can also take the support of AML consultants in the UAE. A professional, AML consultant will be better equipped to help accountants and auditors with the right, relevant measures against money laundering. The consultant will ensure that industry-specific steps are taken in the fight against money laundering and terrorism financing.

Role of AML UAE

AML UAE is a leading AML compliance services provider in UAE. We help you with fulfilling all the requirements for AML and CFT in UAE. Our spectrum of AML compliance services is not restricted to national boundaries, but we also make sure that you comply with the global regulations of AML.

We can help you with:

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Frequently Asked Questions (FAQs)

Here are a few frequently asked questions when it comes to the need and importance of sanction and PEP screening in the customer onboarding process.

Yes, the means of payment used by the client to pay to the auditor or accountant can be an indicator of ML/FT risks. Some of the possible red flags are:

  • If the payment is divided into several, small parts
  • If the relevant documents submitted for the transaction are not trustworthy
  • If the payment is done via an unrelated third party with no connection to the client or no legal explanation for the same
  • If the mode of payment used is such that it hides the true payer of the money. 

The auditor and accountant must have the following information about the beneficial owner of the company:

  • Identification details
  • Source of wealth
  • Corporate history and business activities
  • Business relationships
  • Business transactions with third parties in foreign jurisdictions
  • Any connections with criminals or past allegations of criminal activities

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About the Author

Pathik Shah


Pathik is a Chartered Accountant with more than 25 years of experience in compliance management, Anti-Money Laundering, tax consultancy, risk management, accounting, system audits, IT consultancy, and digital marketing.

He has extensive knowledge of local and international Anti-Money Laundering rules and regulations. He helps companies with end-to-end AML compliance services, from understanding the AML business-specific risk to implementing the robust AML Compliance framework.