The Ministry of Justice supervises law firms, legal consultancy offices, and notaries public through its AML/CTF Department, following Cabinet Decision No. (1/3 W) of 2019 and Cabinet Decision 65 of 2024, which upgraded the AML section into a full department. Ministerial Resolution No. (248) of 2025 sets out the current supervisory procedures and controls. Firms licensed in ADGM are supervised by FSRA; firms licensed in DIFC are supervised by DFSA. 

A law firm should maintain its firm-wide risk assessment; each client risk assessment; CDD and enhanced due diligence files; beneficial ownership information; transaction records and transaction risk assessments for covered activities; sanctions-screening logs, including CNMR and PNMR records and EOCN correspondence; STR decision records and goAML submission receipts; training and attendance records; and a corrective action register. Retention is for five years from the end of the business relationship or completion of the transaction, per the MoJ Guidebook of November 2025 and Cabinet Resolution 134 of 2025. 

Ministerial Resolution No. (248) of 2025, issued on 29 April 2025, replaces Ministerial Resolutions 532 and 533 of 2019. It confirms the MoJ AML/CTF Department as the competent supervisory body for law firms, legal consultancy offices, and notaries public; applies the Cabinet Resolution 71 of 2024 penalty schedule through Article 6; provides a 20-working-day grievance window in Article 7; and requires a 30-working-day response in Article 8. Firms should refresh their sanctions, STR, and governance policies to align with the new instrument. 

Yes. Law firms licensed in Abu Dhabi Global Market are supervised by the Registration Authority and follow the ADGM Financial Services and Markets Regulations together with the FSRA AML Rulebook. Law firms licensed in the Dubai International Financial Centre are supervised by the Dubai Financial Services Authority and follow the DIFC Regulatory Law and DFSA AML Module. These free-zone regimes are distinct from the Mainland MoJ regime described above and are covered on the ADGM and DIFC pages in this cluster.

MoE Circular 08/AML/2021 requires DPMS to file a Dealers in Precious Metals and Stones Report (DPMSR) on the UAEFIU’s goAML platform for every cash transaction at or above AED 55,000 with a resident or non-resident individual, and for every transaction at or above AED 55,000 with a legal entity, whether paid in cash or by wire transfer. Separately, any suspicion of ML, TF or proliferation financing, regardless of amount, must be filed as a Suspicious Transaction Report via goAML, and confirmed and partial name matches against sanctions lists must be filed as CNMR or PNMR within five business days of the freeze or suspension.

Yes. Under Ministerial Decree 68 of 2024 and MoET Circular 2 of 2024, entities that engage in refining or recycling gold must adhere to the 5-step Due Diligence Regulations for Responsible Sourcing of Gold and, additionally, appoint an independent third-party auditor and submit an annual due diligence report on the gold supply chain. The audit obligation has applied since 1 January 2023. Refineries remain subject to all the generic DPMS obligations under Decree Law 10 of 2025 and Cabinet Resolution 134 of 2025 in parallel.

The UAEFIU Strategic Analysis Report on DPMS (September 2025) lists thirty-two sector-specific indicators. The most common include: refusal to provide identification; inability to demonstrate funding sources; forged certificates of origin, refinery stamps or fake invoices; supply chains transiting conflict-affected or high-risk jurisdictions; large or frequent cash transactions inconsistent with the customer’s profile; structuring through multiple visits or split invoices just below AED 55,000; payments via multiple third parties or offshore entities without clear commercial link; and repeated requests for duplicate invoices or refunds after cash purchases.

DPMS established in ADGM and DIFC are supervised by the AFDGM Registration Authority (RA) and the Dubai Financial Services Authority (DFSA), respectively. Their rulebooks implement UAE federal AML/CFT law and the UAE’s international AML/CFT commitments, so the substantive obligations and the AED 55,000 threshold logic track federal law. The procedural touchpoints licensing, inspections, filings and enforcement are, however, with the financial free-zone regulator rather than MoET. DPMS in commercial free zones outside ADGM and DIFC remain under MoET supervision.

Three federal authorities supervise DNFBPs on the mainland and in commercial free zones: the Ministry of Economy and Tourism (MoET) supervises accountants, auditors, TCSPs, dealers in precious metals and stones and real estate brokers and agents; the Ministry of Justice (MoJ) supervises lawyers, notaries and other legal professionals; and the General Commercial Gaming Regulatory Authority (GCGRA) supervises commercial gaming operators. The Dubai Financial Services Authority (DFSA) and the Registration Authority (RA) supervise DNFBPs operating in the DIFC and ADGM, respectively.

 Yes for the federal layer. Every DNFBP is bound by FDL 10/2025, CR 134/2025 and the same DNFBP-wide MoET guidance and circulars. The core obligations, business-wide risk assessment, CDD, beneficial owner identification, sanctions screening, goAML reporting, internal policies, training and record-keeping, are the same. Sector-specific MoET supplemental guidance and the September 2025 DNFBP Guidelines layer on top, calibrated to each sector’s typical customer types and risk drivers.

 All six DNFBP categories warrant a dedicated guide because their CDD trigger activities, customer types and risk profiles diverge. amluae.com publishes individual sector guides for TCSPs, accountants and auditors, lawyers/notaries/legal professionals, real estate agents and brokers, dealers in precious metals and stones, and commercial gaming operators. Each guide explains the sector-specific MoET or MoJ supplemental guidance, registration, goAML enrolment and the typical inspection focus.

Federal Decree-Law No. (10) of 2025 applies across the entire UAE, including the Dubai International Financial Centre and the Abu Dhabi Global Market. The federal AML statute therefore binds DNFBPs in DIFC and ADGM. The difference is operational: in DIFC, the Dubai Financial Services Authority (DFSA) supervises and applies its own AML Module; in ADGM, the Regulatory Authority (RA) supervises and applies its AML and Sanctions Rulebook. For full operational guidance, see our dedicated ADGM and DIFC pages.

Under Article 17(1)(b) of Federal Decree-Law No. (10) of 2025, a Supervisory Authority can impose an administrative fine of not less than AED 10,000 and not exceeding AED 5,000,000 for each violation, alongside warnings, restriction of board powers, suspension of personnel, suspension of activity and revocation of licence. Repeat violations within one year may attract incremental fines. The Unified List under Cabinet Resolution No. (71) of 2024 sets the violation-by-violation tariff for MoJ- and MoE-supervised DNFBPs, and Cabinet Resolution No. (132) of 2023 sets the BO-specific tariff with a three-strike escalation that can include suspension of the commercial licence.

The Ministry of Economy and Tourism (MoET) is the designated AML/CFT supervisory authority for independent accountants and auditors operating in mainland UAE and in commercial free zones. Accountants and auditors licensed in the ADGM are supervised by the FSRA, and those in the DIFC are supervised by the DFSA. Federal AML laws apply in all three jurisdictions; the difference is the operational rulebook and the supervisory interface.

Risk-based customer due diligence is expected. This includes verifying the identity of the customer and all beneficial owners at the 25 per cent ownership or effective-control threshold, understanding the purpose and intended nature of the business relationship, conducting ongoing monitoring of transactions and customer information, and keeping records for at least five years. Enhanced due diligence is required for high-risk customers; simplified due diligence may be applied only to genuinely low-risk relationships where no suspicion of ML or TF exists.

Common red flags for accountants include unexplained large cash transactions or payments in rounded amounts, complex multi-jurisdictional structures with no clear business rationale, clients reluctant to provide identification or beneficial ownership information, inconsistencies between reported revenue and observable business activity, transactions involving high-risk or sanctioned jurisdictions, use of nominee directors or shell companies with no substantive operations, and sudden changes in transaction patterns or payment flows without a clear commercial reason.

Yes. ADGM and DIFC are financial free zones with their own regulatory authorities, the ADGM Registration Authority (RA) and the DFSA respectively. Audit firms licensed in those jurisdictions follow the AML/CFT rulebook issued by their regulator. However, the overarching federal laws and cabinet resolutions, including Federal Decree-Law No. (10) of 2025 and Cabinet Decision No. (134) of 2025, apply across the entire UAE, including ADGM and DIFC. The supervisor and the operational rulebook differ by jurisdiction, not the federal statute.