Introduction: Why Advisory Firms Are Under AML Pressure in 2026

AML enforcement in the UAE has entered a new phase. While banks and real estate firms remain high-risk sectors, advisory, consulting, and accounting firms are now firmly on the regulatory radar.

By 2026, regulators no longer view professional service firms as back-office facilitators. Instead, they are seen as decision influencers—entities that shape transactions, design structures, and legitimize financial activity.

This shift has created AML challenges that are unique to professional firms, and many are still unprepared for the level of scrutiny now applied.

Why Regulators Are Re-Evaluating Professional Service Firms

Criminal networks rarely operate alone. They rely on:

• Advisors to design ownership structures

• Accountants to normalize financial records

• Consultants to justify commercial rationale

• Professionals to prepare compliant documentation

This makes advisory firms early touchpoints in the money-laundering lifecycle—often before funds even reach banks.

Regulators now expect these firms to identify risk, not just deliver services.

Lessons Drawn From the Real Estate Sector

Real estate became a priority AML sector because it allowed:

• Large value transfers in single transactions

• Ownership opacity through layered entities

• Long-term asset parking that hides illicit funds

Advisory and accounting firms frequently operate upstream of these transactions—structuring companies, advising on tax efficiency, and preparing financials.

As a result, regulators recognize that AML risk often originates during advisory engagement, not at the point of transaction.

The Risk-Based Approach Now Applies to Professional Judgment

Under the UAE’s risk-based approach (RBA), compliance is no longer about uniform procedures. It is about where judgment and influence exist.

In line with Financial Action Task Force guidance, firms are expected to:

• Assess client risk beyond documentation

• Question economic substance

• Escalate concerns internally

• Record professional decisions

Failing to exercise judgment is now considered an AML weakness.

AML Challenges Unique to Advisory, Consulting & Accounting Firms

1. “Advisory Distance” From Transactions

Unlike banks, professional firms often do not move funds directly. This creates a false sense of safety.

However, regulators now examine:

• Advice that enables fund movement

• Structures designed to obscure ownership

• Financial statements that legitimize flows

Distance from funds no longer equals reduced AML responsibility.

2. Complex Client Structures and UBO Identification

Advisory firms frequently deal with:

• Holding companies

• Cross-border groups

• Nominee arrangements

• Trust and foundation structures

Identifying the true beneficial owner is often challenging, but regulators expect firms to:

• Understand ownership logic

• Identify control and influence

• Document unresolved uncertainties

“Client-provided information” alone is no longer sufficient.

3. Reliance on Client Explanations

A common AML failure is accepting:

• Business rationale without evidence

• Unusual transactions justified verbally

• Tax-driven explanations without substance

In 2026, regulators expect verification, not acceptance.

4. Inaccurate or Incomplete Financial Records

Accounting firms face a critical risk:

• Weak records can hide illicit activity

• Adjustments without explanation raise red flags

• Inconsistencies undermine AML monitoring

Financial accuracy is now directly linked to AML effectiveness.

5. Informal Escalation Culture

Many advisory firms rely on:

• Partner discussions

• Verbal approvals

• Judgment calls without documentation

Regulators now treat undocumented decisions as non-existent controls.

Regulatory Expectations in the UAE

AML supervision is led by the Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department, operating under the Central Bank of the UAE framework.

During inspections, regulators assess:

• Risk assessments tailored to advisory services

• Escalation procedures and logs

• Evidence of challenge to clients

• Ongoing monitoring practices

Documentation quality often determines inspection outcomes.

Why Manual AML Processes Fail Advisory Firms

Professional firms often depend on:

• Checklists

• Email approvals

• Partner intuition

These approaches fail because they:

• Lack consistency

• Cannot demonstrate governance

• Do not scale with complexity

In 2026, regulators focus on process maturity, not professional reputation.

Special Risk in Emerging and Fast-Growing Markets

In rapidly expanding UAE sectors:

• New advisory firms enter quickly

• AML awareness varies

• Client onboarding pressure is high

Supervisors closely monitor firms operating in:

• New free zones

• High-volume incorporation environments

• Cross-border advisory hubs

Early AML weaknesses often lead to long-term enforcement issues.

Practical Steps to Strengthen AML in Advisory Firms

1. Redefine Client Acceptance Criteria

Firms must document:

• Why a client is accepted

• What risks exist

• How those risks are mitigated

2. Integrate AML Into Advisory Workflows

AML should be embedded into:

• Structuring advice

• Accounting reviews

• Audit planning

• Tax advisory decisions

3. Formalize Escalation and Decision-Making

Every concern should have:

• A written assessment

• A clear decision

• Senior-level review evidence

4. Train Professionals, Not Just Compliance Teams

Partners, managers, and seniors must understand:

• AML red flags

• Risk indicators

• Regulatory expectations

5. Seek Expert AML Support Where Needed

Firms such as Swenta assist advisory and accounting practices by:

• Reviewing AML frameworks

• Strengthening escalation procedures

• Preparing firms for inspections

• Aligning controls with UAE expectations

The Cost of Ignoring These Challenges

Firms that fail to adapt face:

• Regulatory penalties

• Mandatory remediation

• Loss of professional credibility

• Client trust erosion

In 2026, AML failures are viewed as governance failures, not technical oversights.

The UAE’s AML framework has matured significantly. Advisory, consulting, and accounting firms are now recognized as critical gatekeepers in the financial system.

Those who adapt will:

• Reduce regulatory risk

• Strengthen market credibility

• Gain long-term client confidence

Those who don’t will increasingly face enforcement scrutiny.