AML/CFT Compliance Services

Federal Decree Law No (20) of 2018 is a fundamental pillar of the UAE AML/CFT efforts. This Decree stipulated the establishment of:

  • a committee dedicated to AML/CFT objectives, under the chairmanship of the Governor of the Central Bank of the UAE; and
  • an independent Financial Information Unit (FIU) to receive and investigate all reports submitted by financial institutions and other corporate establishments regarding the suspected illicit financial activity.

As implemented by Cabined Decision No (10) of 2019, Federal Decree No. (20) of 2018 has raised the effectiveness of the AML/CFT legal and institutional framework of the nation, in line with FATF requirements and recommendations.

The reporting and regulations under this Regulations have gained momentum with the introduction of the new GoAML Platform and strict guidelines from the regulator.

It is mandatory for the following specified businesses to comply with the Regulations.

Financial Institutions DNFBP’s
-> Receiving deposit and other fund or providing credit facilities.

->  Private banking service

-> Securities, finance, and financial leasing

->  Currency exchange and money transfer

>  Stored value service, electronic payments for retail and digital cash.

-> Preparing and Marketing financial activities

->  Insurance Transactions

->Broker and real estate agents

->Dealers in precious metals and precious stones.

-> Independent legal professionals and accountants.

->Providers of corporate service and trusts.

Failure to keep up with the changing requirements can lead to penalties and legal consequences.

An effective framework should be developed based on the guidelines provided by the regulator in compliance to the Federal Law No 20 of 2018 and Federal Law No. 26 of 2021 amending certain provisions of Federal Law 20, Cabined Decision No. 10 of 2019, Cabined Decision No. 58 of 2020, Cabined Decision No. 74 of 2020 ad the guidelines, circulars, notices, and standards issued from time to time.

The pillars that help to build an effective AML/CFT Compliance Program can be categorized as under:

  1. Corporate Governance: Governance Framework, appointing an AML/CFT Compliance officer & ensuring adequate staff screening.
  2. Policy and Procedures: Establishing, documenting, and updating policies and procedures.
  3. Systems and Controls: Maintaining adequate risk-based customer due-diligence (CDD) and ongoing monitoring procedures.
  4. MIS and Reporting: Reporting and appraising the top management on periodic basis and adhering to reporting guidelines by the Authorities.
  5. Independent Assessment: Review of AML Framework by external expert, identify gaps and suggested corrective action.
  6. Training: Staff Awareness Programs, including senior management and Board.
  7. Documentation: Maintaining adequate records.

What Services do we cover in AML/CFT Compliance?

AML Policy and Procedures:

  • Designing, Reviewing, updating AML/CFT Policy and Procedures
  • Drafting of AML/CFT Policy and Procedures Manuals
  • Reviewing of existing AML/CFT Policy and Procedures
  • Drafting of Anti-Bribery and Anti-Corruption Policy

Risk Assessment and Risk Profiling

  • Review of customer risk assessment methodology.
  • Assisting in development of customer risk assessment model considering NRA guidelines.
  • Assisting in preparation of Risk Register – Risk identification and mitigation.

AML/CFT Health Checkup

  • Gap Assessment
  • Periodic review of onboarding documentation and transactions

Compliance Assistance

  • Assistance in registration on the GoAML Portal.
  • Guidance to AML compliance officer for performing his day to day function.
  • Assisting in conducting EDD for High-Risk customers.
  • Assistance in preparation of statutory reports.
  • Assistance in screening of customers and counterparty
  • Conducting Audits/reviews as per statutory requirements, including agreed upon procedures Audit (AUP Audit)
  • Assistance in preparation of documentation standards.

AML/CFT Health Checkup

  • Conducting AML/CFT awareness program for staffs
  • Conducting AML/CFT awareness program to senior management and board of directors.
  • Conducting role specific awareness programs covering Screening, Transactions monitoring, Due Diligence, etc.
  • Topics covered under AML/CFT awareness program includes;
  • Money Laundering
  • Terrorist Financing
  • ML/TF – Methods and Techniques
  • Stages of Money Laundering
  • Roles and responsibilities of CO/MLRO/and ACO/Deputy MLRO
  • Scope of internal controller/auditor pertaining to AML framework
  • Financial Action Task Force (FATF) – 40 Recommendations
  • International guidelines – EU, UN, EGMONT, etc.
  • AML UAE laws and regulatory guidelines
  • Risk-based approach for AML