Vermeulen Legal Consultancy FZ LLE (Vermeulens) is committed to achieving and maintaining full compliance with the UAE’s Anti-Money Laundering (AML), Combatting the Financing of Terrorism (CFT), and Sanctions regime. This statement outlines our obligations, commitments, and the measures we employ to ensure consistency with prevailing legal frameworks.
Vermeulens is a Designated Non-Financial Business or Profession (DNFBP) and is supervised for AML/CFT purposes by the UAE Ministry of Justice as a legal professional.
1. LEGAL FRAMEWORK
Vermeulens’ compliance framework is guided by the following UAE laws and regulations:
- Federal Decree-Law No. (10) of 2025 on Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing;
- Cabinet Resolution No. (134) of 2025 concerning the Implementing Regulation of Federal Decree-Law No. (10) of 2025;
- Cabinet Decision No. (74) of 2020 concerning UN Security Council Sanctions and Targeted Financial Sanctions (TFS).
- Cabinet Decision No. (109) of 2023 On Regulating the Beneficial Owner Procedures
We further adhere to regulatory guidance provided by the UAE Financial Intelligence Unit (FIU) and the UAE Executive Office for Control and Non-Proliferation.
2. POLICY COMMITMENT
We uphold a strict zero-tolerance policy against money laundering, terrorism financing, and sanctions violations. Vermeulens ensures compliance through the following measures:
- Risk-Based Approach: A risk-based compliance programme is employed, consistent with Cabinet Resolution No. (134) of 2025, to identify, assess, and mitigate AML/CFT risks.
- Customer Due Diligence (CDD): Comprehensive CDD and Enhanced Due Diligence (EDD) measures are implemented where applicable, pursuant to Article 19(1)(b) of Federal Decree-Law No. (10) of 2025 and the applicable provisions of Cabinet Resolution No. (134) of 2025.
- Daily Screening: We utilise automated tools (e.g., Watchdog) to perform daily checks on clients, beneficial owners, and transactions against UAE Local Terrorist Lists and the UN Security Council Consolidated List.
- Suspicious Transaction Reporting (STR): Procedures are in place to promptly file Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) to the UAE FIU via the goAML platform.
- Targeted Financial Sanctions: Obligations under Cabinet Decision No. (74) of 2020 are implemented to ensure prompt freezing of assets or restriction of transactions involving designated persons or entities, as legally required.
- Record Retention: Identification and transactional records are retained for a minimum of five (5) years in accordance with Article 19(1)(f) of Federal Decree-Law No. (10) of 2025 and Article 25 of Cabinet Resolution No. (134) of 2025.
- Employee Awareness and Training: AML/CFT training is mandatory for all staff at least annually, with updates provided in response to significant regulatory changes or identified risks.
- Independent Audits: Regular bi-annual compliance reviews and independent audits are carried out to evaluate the effectiveness of our AML/CFT programme.
3. GOVERNANCE AND RESPONSIBILITY
Money Laundering Reporting Officer (MLRO)
The MLRO oversees the implementation, review, and ongoing management of Vermeulens’ AML/CFT/CPF and Sanctions compliance programme and is responsible for:
- Managing CDD/EDD processes;
- Filing STRs/SARs via the goAML platform; and
- Ensuring organisation-wide compliance with relevant laws.
MLRO Contact Details:
Name: Marthinus Vermeulen
Position: Managing Partner
Email: enquiry@vermeulens.ae
Employee Responsibilities
All employees, including part-time, contracted, or outsourced staff, must:
- Comply with the internal AML, CFT, and Sanctions Policy;
- Actively participate in training initiatives; and
- Escalate any suspicious transactions or irregularities promptly to the MLRO.
Non-compliance may result in disciplinary action, regulatory fines, or, where applicable, criminal liability under UAE law.
4. CLIENT DUE DILIGENCE AND MONITORING
4.1 Verification Obligations
Prior to providing any services, Vermeulens must:
- Verify the identity of the client and ultimate beneficial owner;
- Establish and document the purpose of engagement; and
- Assess the source of funds and wealth of the client.
Enhanced Due Diligence (EDD) is undertaken for high-risk clients, including those with links to high-risk jurisdictions, politically exposed persons (PEPs), or complex ownership structures.
4.2 Suspicious Transaction Identification
Any suspicious transactions, or attempts to circumvent compliance requirements, are promptly reported to the UAE FIU via the goAML platform.
4.3 Payment Restrictions
Vermeulens does not accept:
- Cash payments;
- Cryptocurrency payments; or
- Client funds deposited in trust or escrow accounts.
5. SANCTIONS COMPLIANCE
Vermeulens is committed to full compliance with UAE, UN Security Council, and, where relevant, OFAC/EU sanctions regimes.
5.1 Screening
We perform daily sanctions screening using automated compliance tools updated in coordination with the UAE Executive Office for Control and Non-Proliferation.
5.2 Freezing and Reporting
- Assets or transactions involving designated persons or entities are promptly frozen.
- Relevant matters are reported immediately to the UAE authorities.
5.3 Operational Restrictions
Vermeulens will not provide services to individuals, entities, or jurisdictions where sanctions compliance is at risk.
6. TRAINING AND AWARENESS
Vermeulens provides AML/CFT and sanctions compliance training to all employees on at least an annual basis.
Training content includes:
- Identification of suspicious transaction/activity red flags;
- Awareness of money laundering and terrorism financing typologies; and
- Compliance procedures for CDD/EDD and STR filing.
7. INDEPENDENT AUDITS AND MONITORING
To ensure systemic compliance, Vermeulens undertakes the following measures:
- Bi-annual audits to evaluate internal adherence to compliance obligations; and
- Real-time transaction monitoring and gap reviews of existing processes.
8. CONTACT AND ENQUIRIES
For compliance-related queries or assistance, please contact:
Name: Marthinus Vermeulen
Position: Money Laundering Reporting Officer (MLRO)
Email: enquiry@vermeulens.ae
9. LEGAL NOTICE
This web statement is a summary of Vermeulens’ AML, CFT, and Sanctions compliance obligations under Federal Decree-Law No. (10) of 2025, Cabinet Resolution No. (134) of 2025, and Cabinet Decision No. 74 of 2020 and Cabinet Decision No. (109) of 2023.
It is intended for transparency purposes only and does not constitute legal advice or a substitute for the more comprehensive internal AML/CFT and Sanctions Policy.
10. UPDATES TO THIS STATEMENT
This ANTI-MONEY LAUNDERING, COUNTER-TERRORISM FINANCING, AND SANCTIONS COMPLIANCE STATEMENT was last updated on 7 October 2026. We reserve the right to amend this statement as necessary to reflect changes in applicable laws and regulations and our internal policies and practices. Updates will be reflected here, and, where significant changes occur, we will notify you via appropriate channels.