ANTI-MONEY LAUNDERING

The Federal Decree-Law No. (20) of 2018 On Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations and Cabinet Decision No. (10) of 2019 Concerning the Implementing Regulation of Decree-Law No. (20) of 2018 On Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, as well as various other Cabinet Decisions and Cabinet Resolutions, each as amended from time to time, impose a number of obligations on legal consultancies in the United Arab Emirates as part of the UAE Government's measures to combat money laundering and the financing of terrorism and illegal organisations.

The combined effect of this legislation is to provide a stringent and comprehensive system of client identification procedures, record keeping and mandatory reporting.

When first taking your instructions, we are required to identify both our client and (if relevant) the ultimate beneficial owner of our client, and to verify that identity in a number of ways. We may need your assistance to satisfy these requirements. Without compliance with these obligations, we will not be able to act for you.

Legislation in the UAE and elsewhere may also place us under a legal obligation, in certain circumstances, to disclose confidential information we have about you and your affairs to law enforcement authorities. Our obligations are not optional and we cannot override or avoid them.

We will, of course, ensure that we only report information that we are obliged to report as a matter of law. We may not be able to inform you of the report we have made unless and until permitted to do so by the law enforcement authorities.