Bank accounts and compliance in the UAE

When you need a bank compliance lawyer

• The bank has sent a KYC or Enhanced Due Diligence request with a tight deadline.
• An incoming or outgoing payment is on hold and the bank wants invoices, contracts or shipping documents.
• The account has been restricted or frozen and the relationship manager won't say why.
• The bank has given notice that it is closing the account.
• Your company was refused an account and you need to know what to fix before applying again.

If you have yet to open an account, start with corporate bank account in the UAE, which covers requirements and common reasons for rejection.

How bank compliance works in the UAE

UAE banks must comply with anti-money laundering and counter-terrorist financing law and Central Bank of the UAE requirements. In practice this means periodic reviews of client files, transaction monitoring and sanctions screening. Many banks also follow the requirements of their foreign correspondent banks. Any payment out of line with your profile — a new country, a new counterparty, a sharp rise in turnover — can trigger a request.

It is important to distinguish an internal restriction by the bank from a freeze ordered by a court or a public authority: they are different procedures with different remedies.

The KYC file and source of funds

A good response to a bank is not a pile of documents but a coherent story in which every transaction is explained and evidenced. We gather and prepare:

• corporate documents: licence, MoA, shareholder and beneficial owner (UBO) registers, current visas and Emirates IDs;
• a description of the business model: suppliers, customers, countries, goods or services, expected turnover;
• evidence for specific payments: contracts, invoices, transport documents, correspondence;
• evidence of the shareholders' source of funds and source of wealth;
• a covering letter that ties it all together.

We translate foreign documents into English and legalise them where needed.

Unfreezing an account: our approach

1. Diagnosis (1–2 days). We review the bank correspondence, statements and documents and identify the likely reason for the restriction.
2. Response to the bank. We prepare a complete file and letter and handle compliance's follow-up questions.
3. Escalation. If the bank doesn't respond or the decision is unjustified — a formal complaint to the bank, then a referral to the Sanadak financial ombudsman.
4. If the bank closes the account — we press for return of the balance and prepare an application to another bank in parallel.
5. If a court or authority ordered the freeze — we work within that procedure; where a creditor dispute is involved, our litigation team steps in.

Timing depends on the bank and the issue. We cannot guarantee the bank will keep the account — the decision is theirs — but a complete, consistent response materially improves the odds.

Prevention: keeping the account open

• Update the bank promptly: renewed licence, visas, changes of shareholders.
• Tell the bank in advance about new business lines and large payments.
• Keep contracts and invoices for every payment readily available.
• Keep the UBO register and tax registrations up to date — see tax and compliance.

These tasks are easiest to handle within corporate legal support.

Fees

Consultation from AED 750 / 60 min (credited if you sign a contract). Preparing a response to the bank or supporting an account opening is a fixed-price project from AED 5,000. Ongoing support, including handling bank requests, is a retainer from AED 3,500/month. We work remotely, in Russian or English, and send a progress report every week.