1. Why we ask
Under UAE Federal Decree-Law 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, and Cabinet Decision 10 of 2019 (as amended by Cabinet Decision 24 of 2022), Designated Non-Financial Businesses and Professions (DNFBPs) — including UAE law firms — are required to conduct Customer Due Diligence (CDD) on each new client and to monitor matters on an ongoing basis. We are registered with the relevant supervisory authority and apply a risk-based approach.
2. What we ask for
For individual clients: a copy of a current passport (and Emirates ID for UAE residents), proof of residential address (utility bill, bank statement or tenancy contract issued within the last 3 months), and source-of-funds and source-of-wealth information for higher-value or higher-risk matters.
For corporate clients: trade licence (current), Memorandum and Articles, register of shareholders, ID for the ultimate beneficial owner(s) (≥ 25% interest), proof of registered office address, and authority of the person instructing us.
For trusts, foundations and other arrangements: the constitutive document, register of beneficiaries / council, and ID for the founder, council members, beneficiaries and any protector.
3. Enhanced due diligence
We apply enhanced due diligence for higher-risk situations including: politically exposed persons (PEPs); clients or counterparties in higher-risk jurisdictions on the UAE National Risk Assessment list; complex ownership structures with no apparent commercial rationale; matters involving sanctioned parties or sanctioned cargoes; and any matter where the source of funds is not transparent. Enhanced due diligence may include senior-management approval, additional information about the source of wealth, and ongoing monitoring.
4. Sanctions screening
We screen all clients, counterparties and beneficial owners against UAE Cabinet Decision 74 of 2020, the UN Consolidated Sanctions List, OFAC, OFSI and EU sanctions lists at onboarding and at periodic intervals during the matter.
5. Reporting obligations
Where required by law we file Suspicious Transaction Reports or Suspicious Activity Reports with the UAE Financial Intelligence Unit (FIU) through the goAML platform. UAE law prohibits us from informing the client that a report has been filed ("tipping off").
6. Record retention
We retain CDD records and matter files for a minimum of five years from the closure of the matter as required by FDL 20/2018, and longer where required by other regulation or by the firm's professional-conduct rules.
7. What this means for engagement timing
We cannot accept funds or commence substantive work until CDD is satisfactorily completed. For most matters, CDD takes 1–3 business days from receipt of the requested documents. For complex structures or higher-risk matters, it can take longer. We aim to be transparent about CDD timelines at the engagement-letter stage.
8. Confidentiality
Information collected for CDD purposes is treated as confidential and processed in accordance with our Privacy Policy. It is shared only with the personnel and competent authorities entitled to receive it under UAE law.
9. Contact
Compliance enquiries: compliance@almaazmilawyers.com · +971 4 241 3555.
This page is provided for information only. It does not create a solicitor–client relationship. For matter-specific advice, please speak to us.