01
Records that do not reconcile
Revenue, cash flow or assets that cannot be explained by the client's actual business activity.
Risk indicators
What suspicious looks like in accounting
Accountants and auditors are well placed to see laundering because it shows up in the numbers. These are the patterns that should prompt a closer look and a record of your reasoning.
02
Round-tripping and circular flows
Funds that move between related entities and back with no genuine commercial purpose.
03
Cash that overwhelms the model
A business reporting far more cash than its sector or size would normally generate.
04
Opaque ownership
A client structure built to obscure who ultimately owns or controls the business.
05
Reluctance to provide records
A client who resists supplying the documents a normal engagement would require.
06
Transactions without substance
Invoices or contracts that appear designed to justify a movement of money rather than reflect real trade.
The regulatory stakes
The cost of getting it wrong
Accounting and audit firms within the DNFBP regime are supervised for anti-money laundering and counter-terrorist financing (AML and CTF) compliance. These figures show the scale of what the regulator can impose where obligations are not met.
AED 5,000,000
Maximum administrative fine per violation
The range runs from AED 10,000 to AED 5,000,000 for each violation, under Article 17 of Federal Decree-Law No. 10 of 2025.
Licence
Suspension or restriction of the right to practise
The supervisory authority can suspend or restrict the profession, restrict the powers of managers and owners, or revoke the licence. Article 17 of Federal Decree-Law No. 10 of 2025.
Self-check
Are you in scope?
If any of these describe your work, UAE law may treat you as a Designated Non-Financial Business or Profession with AML obligations. Tick what applies.
You may carry AML obligations
Accountants and auditors fall within the UAE DNFBP regime for qualifying activities. That can mean goAML registration, client due diligence, beneficial ownership verification and reporting. We help you scope and meet exactly what applies to your firm.
0 of these apply to you
How we help Accounting & Audit Firms
What we do
We help accounting and audit firms meet their AML and CTF obligations in a way that fits professional practice, from scoping in-scope work through to due diligence, reporting and staff readiness.
01
Scoping and Registration
We identify which of your services fall within the DNFBP regime and register the firm where required.
In-scope activity assessment
A clear view of which engagements trigger AML duties and which do not.
goAML registration
Registration with the UAE Financial Intelligence Unit (FIU) where your work requires it.
Reporting workflow
A documented route from a concern to a timely Suspicious Transaction Report (STR).
02
Client Due Diligence and Ownership
We design Customer Due Diligence (CDD) and beneficial ownership checks that fit accounting and audit engagements.
- Client identification and verification
- Beneficial ownership verification
- Enhanced Due Diligence (EDD) for higher-risk clients
03
Procedures and Trained Staff
We give your team clear procedures and the training to apply them as part of normal client work.
- Red flag awareness for client-facing staff
- Internal escalation and reporting route
- Documented training records for inspection
How we get you compliant
From scoping your obligations to a working reporting routine, built around professional practice.
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