Lawyers, notaries, other independent legal professionals and accountants. This refers to sole practitioners, partners or employed professionals within professional firms. It is not meant to refer to internal professionals that are employees of other types of businesses, nor to professionals working for government agencies, who may already be subject to AML/CFT measures
Trust and Company Service Providers. This refers to all persons or businesses that are not covered elsewhere under these Recommendations, and which as a business, provide any of the following services to third parties:
acting as a formation agent of legal persons
acting as (or arranging for another person to act as) a director or secretary of a company, a partner of a partnership, or a similar position in relation to other legal persons
providing a registered office, business address or accommodation, correspondence or administrative address for a company, a partnership or any other legal person or arrangement;
acting as (or arranging for another person to act as) a trustee of an express trust or performing the equivalent function for another form of legal arrangement
acting as (or arranging for another person to act as) a nominee shareholder for another person
DNFBPs play a key role in protecting financial systems and economies from ML and TFS risks.
As gatekeepers, they are exposed to tremendous amounts of information, and act on behalf of their customers in many transactions. Some of these transactions are highly vulnerable to ML/TFS risks due to the nature of the product or service offered by DNFBPs. Some examples could be the following:
FATF recommendations set the main requirements and expectations from DNFBPs, under the UAE Federal Law, where DNFBPs are required to meet certain obligations. ADGM AML rules specify these obligations under FATF recommendations and UAE Federal Law.
All relevant persons who are conducting one or more of the activities classified as DNFBPs are required to be in compliance.