To comply with UAE Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and

Proliferation Financing (PF) regulations, DNFBPs in UAE must adhere to specific requirements. Here’s a detailed overview:

1. Understanding Regulatory Framework
   • AML Law: Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations.
   • Executive Regulation: Cabinet Decision No. 10 of 2019 on the Implementing Regulation of Federal Decree-Law No. 20 of 2018.
   • Guidance: Follow the guidelines issued by the UAE Ministry of Economy for Designated Non- Financial Businesses and Professions (DNFBPs).
2. Customer Due Diligence (CDD)
   • KYC (Know Your Customer): Implement procedures to identify and verify the identity of clients before entering into a business relationship.
   • Beneficial Ownership: Determine and verify the identity of beneficial owners of properties being bought or sold.
   • Ongoing Monitoring: Continuously monitor transactions and update customer information based on risk assessment.
3. Risk Assessment
   • Business Risk Assessment: Conduct a comprehensive risk assessment to understand the AML, CTF, and PF risks specific to their business.
   • Customer Risk Profiling: Assess the risk level of each customer based on factors like nationality, source of funds, and the nature of the transaction.
4. Record-Keeping
   • Retention Period: Maintain records of customer identification, transaction details, and CDD information for at least five years after the end of the business relationship.
   • Accessibility: Ensure that records are accessible for examination by authorities if required.
5. Reporting Obligations
   • Suspicious Activity Reporting (SAR): Report any suspicious activities or transactions to the UAE Financial Intelligence Unit (FIU) through the “goAML” system.
   • Threshold Reporting: Report cash transactions above AED 55,000 and any transfers involving high-risk countries or individuals/entities listed on sanctions lists.
6. Policies and Procedures
   • AML/CTF Policy: Develop, implement, and regularly update an AML/CTF policy tailored to the company’s specific risks and operations.
   • PF Compliance: Implement procedures to ensure compliance with UAE’s sanctions and export control regulations to prevent proliferation financing.
7. Employee Training
   • Regular Training: Provide ongoing AML, CTF, and PF training to employees, focusing on identifying red flags, conducting due diligence, and reporting suspicious activities.
   • Record of Training: Maintain records of all training sessions conducted, including attendance and topics covered.
8. Internal Controls and Independent Audit
   • Internal Controls: Establish strong internal controls to ensure compliance with AML/CTF/PF requirements, including a designated Compliance Officer responsible for overseeing the AML program.
   • Independent Audit: Conduct periodic independent audits to evaluate the effectiveness of AML/CTF/PF compliance programs.
9. Registration
   • MoE Registration: Ensure the company is registered with the Ministry of Economy as a

DNFBP

• EOCN Registration: Ensure the company’s email is registered with EOCN to receive the updated list for UAE local & UNSC Target Financial Sanctions.

10. Sanctions Screening
    • Sanctions Lists: Regularly screen customers and transactions against international and UAE- specific sanctions lists to prevent dealings with sanctioned individuals, entities, or countries.
    • Freezing Obligations: Freeze assets and report any dealings with sanctioned individuals/entities as required by UAE law.
11. Penalties for Non-Compliance
    • Be aware of the substantial fines, imprisonment, and potential suspension of business activities for non-compliance with AML, CTF, and PF regulations.

Adhering to these requirements will help your business meet the UAE AML, CTF, and PF obligations and mitigate the risks associated with money laundering, terrorism financing, and proliferation financing.