Jordan AML Obligations for Accountants: Law No. 20 of 2021

Jordan's anti-money laundering (AML) framework for accountants sits in the Anti-Money Laundering and Counter Terrorist Financing Law No. (20) of 2021, which the country's Anti-Money Laundering and Counter Terrorist Financing Unit (the Unit) publishes on its website. This guide sets out what the Law says about accountants and the penalties it provides, and lists what we could not confirm. It is general information, not legal advice.

When accountants are covered

Article 14 of the Law lists the entities it applies to. Financial institutions are in article 14(1). Designated non-financial businesses and professions are in article 14(2), and they include real estate firms, dealers in precious metals and stones, and lawyers, other independent legal professionals and accountants when they prepare or carry out certain client transactions. The activities listed include property sales, managing funds, managing bank accounts and company formation. Auditors are not named in the text we read, and accountants are covered only for the listed client activities. The Cabinet can extend the Law to other entities, professions or activities.

That means an accounting practice should map its services against the list. A firm that only prepares financial statements for a client may be outside the definition for that work, but one that holds client money or sets up companies is likely within it. Take local advice on borderline services.

Customer due diligence

The Law defines customer due diligence as identifying and verifying the customer or beneficial owner so that the entity can assess its risk. Article 15 requires standard, simplified or enhanced due diligence depending on risk, bars anonymous and fictitious-name accounts and dealings with unidentified persons, and requires procedures to identify politically exposed persons and apply specific measures to them. Article 16 says that if due diligence cannot be completed the entity must not open the account, carry out the transaction or continue the relationship, and may report to the Unit. Where doing due diligence could alert the customer, the entity may skip it and file a report instead.

The Law defines a beneficial owner as the natural person who ultimately owns or controls a customer, directly or indirectly. For the general method, see our guides to KYC and customer due diligence in accountancy practices and to politically exposed persons.

Reporting suspicious transactions and tipping off

Under article 18, an entity must notify the Unit immediately of any suspicious transaction or activity, including an attempt, regardless of the amount. The trigger is suspicion or reasonable grounds for suspicion. Under article 10, the Unit may require a reported transaction to be suspended for up to five working days. Article 19 bars entities, directors, employees and staff from disclosing that a report has been filed, with exceptions for certain directors, compliance staff, group financial institutions and legally authorised bodies. Our guide to suspicious activity reports and tipping off is UK-focused but explains the practical sequence of spotting, escalating and reporting.

Record keeping

Article 17 sets out the retention periods. Transaction records and supporting data are kept for at least five years from completion of the transaction. Customer due diligence records, account files, business correspondence and analysis results are kept for at least five years from the end of the relationship or the transaction date, whichever is longer. Records must be updated periodically.

Penalties

Article 31 sets criminal penalties, in Jordanian dinars (JD):

• Failing to report a suspicious transaction under article 18: up to three years' imprisonment, or a fine of JD 10,000 to 200,000, or both.
• Breaching the tipping-off provision in article 19, or article 13(b) and (c): at least six months' imprisonment, a fine of JD 5,000 to 10,000, or both.
• Breaching articles 10, 15, 16 and 17 and article 26(a)(5): up to one year's imprisonment, or a fine of JD 2,000 to 20,000, or both.

Article 32 provides for fines on legal persons of at least double the funds involved, up to JD 500,000, with possible suspension or cancellation of business. Article 34 lists administrative measures, including written warnings, fines up to JD 100,000, restrictions on activity, and licence suspension or revocation. Article 35 sets fines of JD 5,000 to 20,000 for refusing or obstructing the Unit.

What we could not confirm

• Which authority supervises accountants. Article 2 lists supervisory authorities such as the Central Bank, the Securities Commission, the Companies Control Department and the Ministry of Industry, Trade and Supplies, but the text we read did not assign accountants to one of them.
• The date of publication in the Official Gazette, and any later amendments to the Law.
• Any instructions the Unit or a supervisor has issued specifically for accountants.
• Whether the Law uses a specific term for a compliance officer. The text we read refers to compliance staff and requires internal policies and controls.

Suggested next steps

These are our suggestions, not requirements. List your services and mark which ones fall within article 14(2). Confirm in writing with the Unit or a Jordanian lawyer which authority supervises your practice. Write down how staff escalate a suspicion so that a report can go to the Unit immediately. For team training, see our CPD courses.

Frequently asked questions

Are accountants in Jordan covered by AML law?

Under article 14(2) of Law No. 20 of 2021, accountants are covered when they prepare or carry out the listed client transactions, such as managing funds or forming companies.

How quickly must a suspicion be reported?

Immediately, according to article 18, regardless of the amount.

How long must records be kept?

At least five years, under article 17, with the period running from the end of the relationship or the transaction date for due diligence records, whichever is longer.