Qatar AML for Accountants: MOCI Rules and the QFIU

In Qatar, auditors and chartered accountants are supervised for anti-money laundering (AML) by the Ministry of Commerce and Industry (MOCI), not by their professional body. The legal base is Law No. 20 of 2019 on Combating Money Laundering and Terrorism Financing, and MOCI has turned it into concrete steps through circulars. This guide works from those MOCI documents and from the text of Decree-Law No. 19 of 2021, which amended the 2019 Law. It flags where we could only rely on a secondary summary.

Who supervises accountants

MOCI's AML/CFT Section says it supervises, monitors and inspects chartered accountants, dealers in precious metals and stones, and trust and company service providers. The Section can propose financial and administrative sanctions to the Qatar Financial Information Unit (QFIU) and drafts instructions and guidance for the businesses it supervises. MOCI's page cites Decision No. (95) of 2019 as the decision that created the Section.

A later MOCI circular describes the entities under its supervision as dealers in precious metals or precious stones, statutory auditors, investment fund service providers and companies. Wording differs between documents, so treat "auditor" and "chartered accountant" as both likely to be in scope and confirm your position with MOCI. Firms based in the Qatar Financial Centre are a separate matter, since the QFC has its own AML rules and regulator, and we do not cover them here.

Circular No. 7 of 2020: the compliance rules

MOCI's Companies Affairs Department issued Circular No. (7) of 2020 on 16 September 2020. It applies the MOCI Compliance Rules, issued by MOCI Decision No. (48) of 2020 under Law No. 20 of 2019, to auditors (chartered accountants), dealers in precious metals or stones, and trust and company service providers supervised by MOCI. It requires, among other things:

• appointing a compliance officer and a deputy, notified to the AML/CFT Section with a copy to the QFIU;
• an AML/CFT programme proportionate to the firm's risk and size, which the circular asked firms to submit by 15 December 2020;
• a business risk assessment under a risk-based approach;
• screening of staff on hiring and ongoing AML/CFT training;
• testing and review of compliance, with a record submitted to MOCI by 31 July 2021 and every two years after that;
• customer due diligence, including beneficial owners and politically exposed persons, with enhanced measures for high-risk cases;
• record keeping of domestic and foreign transactions and due diligence data for at least ten years.

For a sole practitioner, the circular says the individual must personally take on the senior management and compliance officer roles, or may designate a qualified employee as compliance officer. For background on the due diligence itself, see our guide to customer due diligence in accountancy practices.

Reporting to the QFIU

The circular requires suspicious transactions, including attempted ones, to be reported to the QFIU "promptly", and requires the firm to tell the MOCI AML/CFT Section in writing each time it has reported, without giving the report's details. It sets no number of days. A K&L Gates client alert from January 2020 says the Law requires reporting within three days of forming a suspicion. We have not been able to check that against the Law text, so confirm the deadline in the Law and the Implementing Regulations.

Circular No. 4 of 2025: the Inspections Portal

On 29 December 2025 MOCI issued Circular No. (4) of 2025 on registration at its AML/CFT Inspections Portal. It applies to the DNFBPs under MOCI supervision, which it lists as including statutory auditors. In summary:

• every covered firm must register on the Portal, which is the official channel with the AML/CFT Department;
• each firm must appoint its own compliance officer and deputy, and sharing them across entities needs prior written approval;
• senior management must upload the required documents, including the registration certificate, officers' IDs and CVs, the approved AML/CFT programme, the risk assessment, the KYC policy, the officer's annual report, the independent audit report, the training programme and records such as the suspicious transaction log;
• this was due within 15 days of the circular's issue, which on our count was about 13 January 2026;
• failure exposes the firm to the penalties in Article (44) of Law No. 20 of 2019.

If you were not registered by then, treat it as urgent and ask MOCI how it wants late registrations handled.

What Decree-Law No. 19 of 2021 changed

The Decree-Law, issued on 10 October 2021, replaced several provisions of the 2019 Law. The ones relevant to accountants are Article 20, which requires DNFBPs to give due diligence information and records to the authorities on request without delay, and Article 48, which requires administrators, liquidators and authorities to keep required records for at least ten years from dissolution or from when the entity stops being a customer. It also raised terrorism financing penalties. It does not define DNFBPs or set a reporting deadline.

Penalties

MOCI's circulars refer to administrative and financial sanctions under Article (44) of the Law without giving amounts. The K&L Gates alert summarises Article 44 as allowing fines of up to QAR 1,000,000 on managers and directors, and up to QAR 100,000,000 on an entity or QAR 25,000 per day of non-compliance. Those figures are from a law firm summary, not from the Law text, so verify them before relying on them.

What we have not covered

• The full text of Law No. 20 of 2019 and its Implementing Regulations, which we could not open.
• MOCI Decision No. (48) of 2020 itself.
• Any MOCI guidance issued after the 2025 circular.
• Whether goAML registration is required. The circulars we read do not mention it.

Practical steps: our suggestions

These are our suggestions, not MOCI requirements.

1. Confirm in writing with the AML/CFT Section that your firm is under MOCI supervision.
2. Check that your Inspections Portal registration is complete and your officers' details are current.
3. Diarise the two-year compliance testing record.
4. Keep records for at least ten years.
5. Write a reporting procedure that can reach the QFIU quickly, and ask MOCI what deadline applies.

For comparison, see our guides to Saudi Arabia and Ghana.

Frequently asked questions

Which body supervises accountants in Qatar?

MOCI, through its AML/CFT Section, according to MOCI's own page and circulars.

How long must records be kept?

At least ten years, according to MOCI Circular No. 7 of 2020.

Do I need to register with MOCI?

Circular No. 4 of 2025 requires firms under MOCI's supervision to register on its AML/CFT Inspections Portal.

This guide is general information, not legal advice.