AML Requirements for Lawyers, notaries and legal professionals in ADGM
Law firms, legal consultancy offices and notaries, whether or not they currently perform the transactions listed in Article 3(4).
Are lawyers, notaries and legal professionals designated in ADGM?
Yes. The designation follows the business itself, so a firm carrying on this activity in ADGM is within the regime without any further test.
- Designating provision
- ADGM AML Rulebook, DNFBP definition (e)
- Supervisor
- ADGM Registration Authority
A Legal Professional is a DNFBP by entity here. The federal Article 3(4) activity test does not apply. Note that Ministerial Resolution No. (248) of 2025, Article 3(1) applies the Ministry of Justice's supervisory regime to law firms and legal consultancies in the free zones and financial free zones as well, with Article 3(2) allowing delegation to the free zone authority.
Reports filed with no suspicion required
No threshold-based report has been established for this sector in ADGM. Reporting here is suspicion-driven: suspicious transaction and activity reports are filed when the firm has grounds to suspect, whatever the amount. That is not the same as saying nothing is owed, and it is why record keeping and the ability to recognise a suspicion matter more in this sector than any threshold.
What the regime requires here
ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML), made by the FSRA under the Financial Services and Markets Regulations 2015 governs AML in ADGM. Every designated firm owes the same spine of obligations: a documented risk assessment covering money laundering, terrorist financing and proliferation financing; customer due diligence with enhanced measures for higher risk and for high-risk countries; policies approved by senior management; a compliance officer at management level; an independent audit of the controls; immediate implementation of targeted financial sanctions; staff training; and records available to the authorities on request.
- ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML)
- ADGM Financial Services and Markets Regulations 2015
What Federal Decree-Law No. 10 of 2025 changed sets out the obligations and the penalties in full, with each article cited.
See where this firm actually stands
AML Compass assesses a lawyers, notaries and legal professional against the duties that apply in ADGM, scores its risk and inspection readiness, and produces a report of the gaps citing the provision behind each one.
The same sector elsewhere in the UAE
The designation, the threshold and the supervisor are not the same across jurisdictions, so a firm operating in more than one needs both answers.
This page summarises published legislation and rulebooks for general information. It is not legal advice, and it does not replace the texts themselves or guidance from your supervisor.