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Risk Advisory

Guide to AML in the UAE

November 22, 2023

Many businesses must do extensive customer due diligence under Money Laundering Regulations to prevent money laundering and economic crime. Anti-Money Laundering (AML) checks is an essential aspect of customer due diligence as it aids in screening clients against politically-exposed person (PEP) and Sanctions lists and verify claimed identities. Failure to comply with AML standards can result in financial penalties and, in extreme cases, disqualification as a business/director. At MBG, we specialize in creating AML risk assessment frameworks advising on risk, finance and legal compliance related matters.

What are the AML Regulations in the UAE?

  • Federal Law No. 20 of 2018 – AML and combating the financing of terrorism and illegal organizations
  • Cabinet Decision No (10) of 2019 – concerning implementation of regulation of decree law no. (20) of 2018 on AML and combating finance terrorism and illegal organizations
  • Notice No. 79/2019 dated 23/06/2019 - procedures for AML and Combating of the Financing of Terrorism

What is the recommended approach for AML - Ongoing Monitoring of Customers?

Primary elements of a risk-based approach in AML compliance

  • Customer risk
  • Industry risk
  • Product/service risk
  • Geographic risk
  • Delivery channel risk

How can MBG’s Risk-Based Approach support implementation of AML?

  • MBG can support in establishing and enhancing effective customer due diligence (CDD) and know your customer (KYC) protocols to validate the legitimacy and authenticity of the customers.
  • Conduct thorough screenings of both new and existing customers against international and domestic sanctioned lists.
  • Check new and existing customers against the list of PEPs, recognizing that changes in political status can alter the risk of money laundering.
  • Scrutinize new and existing customers against adverse media, particularly when customers are associated with negative news or implicated in manipulative activities.
  • Designate a dedicated AML compliance officer with the authority to detect any activities that may directly or indirectly indicate money laundering threats.

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