These four sectors are common DNFBP categories. Scope depends on the work performed, not just the business name. This is not an exhaustive list.
Law firms and legal professionals
Lawyers, notaries and independent legal professionals are covered when preparing or carrying out specified client transactions: property purchases or sales, managing client money or accounts, company funding, or establishing, managing or buying and selling businesses or legal arrangements.
Legal professional secrecy has specific reporting exceptions; it is not a blanket exemption for every legal engagement. Assess the matter under the applicable law and Ministry of Justice guidance.
Accounting and audit firms
Independent accountants fall within scope for the specified client transactions described above. MoET also publishes guidance for independent accountants and auditors. Assess the engagement and supervisory requirements; do not assume every bookkeeping task has the same scope.
A useful review starts with the client acceptance file, ownership information, engagement purpose and how staff escalate unusual matters.
Real estate agents and brokers
Covered when concluding property purchase or sale transactions or settlements for clients. Review the buyer, seller, beneficial owners and payment arrangements. Assess whether a Real Estate Activity Report (REAR) is required under the applicable reporting rules, separately from suspicious reporting.
For example, an unexplained third-party payment should prompt review. It is not, by itself, proof of wrongdoing.
Precious metals and stones dealers
The DNFBP cash-transaction trigger is AED 55,000 or more, including apparently linked transactions. This can affect gold, jewellery and precious stones businesses. Apply the DPMSR rules explained below; do not treat that threshold as an exemption from suspicious reporting.
A practical review can check customer files against invoices, payment records and the documented reason for escalation.
