Anti-Money Laundering and Combating The Financing Of Terrorism (AML/CFT)


Anti-Money Laundering and Combating The Financing Of Terrorism (AML/CFT)

UAE’s strong commitment to adopt the finest international business practices has no limits. In April, 2020 the Financial Action Task Force (FATF) issued a Mutual Evaluation Report (MER) on the UAE’s compliance level with the FATF 40 recommendations and the level of effectiveness of the existing compliance system. The evaluation also aimed in identifying the threats, vulnerabilities and emerging risks in the UAE’s financial sector. Pursuant to this Central Bank of UAE(CBUAE) established a dedicated wing to handle all Anti-Money Laundering and Combatting the Financing of Terrorism issues.

Relevant Legislations:

Federal Decree Law No. 20 of 2018 supplemented by Cabinet Decision No. 10 of 2019 is the foundation to AML/CFT compliance framework in UAE. Cabinet Decision No. 58 of 2020 regulating beneficial owner procedure and Cabinet Decision No. 74 of 2020 regarding Terrorism List Regulation and Implementation of UN Security Council Resolutions on Suppression and Combatting of terrorism give additional guidance to the governance framework.

AMLimg (1)


  • Money Laundering: In simple terms, the act of concealing the identity of the original source of illegal funds and then making it appear as derived from a legitimate source.
  • Financing Terrorism: The act of funding or financing any terrorist organisations/activities.

Applicability of the AML/CFT Framework?

Financial Institutions Designated Non-Financial Businesses and Professions (DNFBPs)
Receiving deposits and other funds Brokers and real estate agents
Private banking services Dealers in precious metals and precious stones
Providing credit facilities of all types Independent legal Professionals and accountants
Currency exchange and money transfer services Providers of corporate services and trusts
Stored value services, electronic payments
Virtual banking services
Insurance transactions


1. Appropriate internal policies, procedures and controls to identify and mitigate the risk of ML/FT crimes. This includes:
Conducting customer due diligence: FI & DNFBPs should undertake CDD measures in the following cases:

  • Establishing business relationships
  • Carrying out occasional transactions with a customer for amounts>=AED 55,000.
  • Carrying out occasional wire transfers of amount>= AED 3,500
  • Suspicious transactions
  • Where there are doubts about the adequacy of previously obtained customer data.
    Establishing adequate KYC procedures to identify the customer and assess the risk

Establishing adequate KYC procedures to identify the customer and assess the risk

Screening of your customers: Identify if your customer falls under the sanction list issued by the United Nations Security Council or any local list. Both the list can be accessed from UAEIEC.GOV.AE. Also the entities should subscribe to the UN & Local Sanction mailing list to receive information on their update.

Risk based profiling of your customers: Entities should categories their customers based on the risk factors like:

  • Customer risk : Enterprise level/ Business relationship specific
  • Geographic risk
  • Product, service, transaction value risk
  • Delivery channel related risk
  • Other factors as considered appropriate for the entity.

Enhanced Due Diligence: Once customers are categorized based on risk, enhanced due diligence should be done for customer under High-risk category including Politically Exposed Persons(PEPs). Special approval from senior management should be taken for transactions with customers in this category. A well set KYC policy helps identifying if a particular customer needs EDD.

2. Suspicious Transactions Reporting: Any suspicious transactions should be reported to the Financial Intelligence Unit (FIU) without any delay.
3. Record Retention: All the relevant records, documents and supporting should be retained for a minimum period of 5 years so as to enable the authorities to trace and identify any crimes under AML/CFT.
4. Appoint an AML/CFT Compliance Officer: This is crucial to setting up of an effective AML/CFT overseeing framework. The compliance officer shall be in house employed or outsourced. It’s the duty of the compliance officer to report any crimes of money laundering or terrorism financing, managing the AML/CFT governance in the organization and giving appropriate training and awareness to the management and employees.

Fines & Penalties:
A list of penalties has been issued by the supervisory authority ranging between AED 50,000 to AED 5,000,000.



A general guidance to identify suspicious transactions include:

  • No economic purpose to the transaction
  • Geographic location of the customer
  • The channel through which the transaction is routed.
  • Inability of the customer to give required information or documentation or explain particular transaction.
  • Deposits immediately followed by withdrawals.
  • Using a single bank account for multiple business.
  • Unusual forms of payments like use of traveler’s cheques.
  • Unusual payment terms.
  • For DPMS: Where Trading is happening in large volumes with countries which are not part of a specific precious metals and stones pipeline.
  • Details of transaction different from details in the commercial invoice.
  • Mortgages are repayed quickly without appropriate explanations.
  • If the collateral provided for a transaction is located in a high – risk country or owned by a high-risk organization.

What Elevate can do for you?

  • Prepare and document AML/CFT Policies, Procedures and Controls.
  • Compliance Assistance including notifying relevant updates and guiding to adhere the same.
  • Registration on GoAML Portal.
  • AML/CFT Awareness and Training programs.
  • Know your Customer checks.
  • Gap Assessment and providing periodic review.
  • Provide periodical MLRO Report.