Creating an AML Program for an Entity in the UAE
For businesses in the UAE, including banks, payment providers, exchange houses, and other regulated financial institutions, constructing an AML/CFT (anti-money laundering / counter-terrorism financing) compliance program is both a legal requirement and a critical risk-management step. The Central Bank of the UAE (CBUAE) recently issued updated guidance to help licensed institutions meet their AML/CFT obligations.
Here are the essential elements you need to build into your AML program:
Risk-Based Customer Due Diligence (CDD): Under the CBUAE’s 2023 guidance, institutions must assess and document risks associated with different customer types, including virtual-asset service providers (VASPs), and apply enhanced due diligence when appropriate.
Governance & Compliance Function: Create a dedicated compliance team with defined roles, reporting lines, and board-level oversight. Your AML program should reflect the risk assessment and be formally approved by senior management.
Policies & Procedures: Your internal policies should cover CDD, EDD, transaction monitoring, sanctions-screening, suspicious activity reporting, and record-keeping. CBUAE guidance requires these policies to be proportionate to your business and to evolve as risks change.
Transaction Monitoring & Sanctions Screening: Implement systems that filter customer data and transactions against international and UAE-specific lists, such as the UN Consolidated List and the UAE’s own designated person list.
Training & Culture: Build an AML training program to educate staff on risk indicators, customer profiles, and reporting procedures. CBUAE expects periodic training aligned with your risk framework.
Independent Testing: Your program should be periodically reviewed, validated, and tested to ensure effectiveness. CBUAE guidance requires systems to undergo independent validation and audit.
Reporting to UAE FIU: Use the UAE’s goAML portal to submit suspicious transaction reports. Maintain strong governance and documentation so your reporting is defensible.
Implementing a robust AML program helps you comply with legal obligations and builds trust with partners, regulators, and customers, especially important in a rapidly growing financial market like the UAE. Our team at Platino Consulting specializes in building and refining AML programs tailored to UAE regulations. We provide risk assessments, policy development, monitoring system design, training, and independent testing, giving you peace of mind and operational resilience.
