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AML & CFT.

AML (Anti-Money Laundering) generally, refers to laws, rules/regulations, guidelines and procedures set in place to prevent disguising of illegitimately gained funds as legitimate income in the financial system which is usually done through cycle of transactions that help the proceeds to become legitimate.

CFT (Counter Terrorist Financing): Refers to counter activities that provide financial support to individual terrorists or terrorist groups. Includes funding to banned organisation through business or personal channels.

AML & CFT comprise of three stages:
• Placement
• Layering
• Integration

In the current global trading system, most businesses and companies are directly or indirectly within the ambit of local or international regulations related to AML & CFT.

The FATF further mandates strict compliance to such requirements. Not just the Banking or Financial Services, entities engaged in Insurance, Capital Markets & Securities, Real Estate,Management Consultancies, DNFPBs (Designated Non-Financial Businesses and Professions), etc. are governed by AML Regulations.

For organisations it is important to ensure compliance to regulatory requirements under AML & CFT. A business within the requirement of AML & KYC must ensure:

• To have AML & CFT Policies.
• Meet the international KYC standards.
• Provide and Ensure UBO Documents.
• Ensure the elements for Risk Assessments on Customer/Client/Dealer/Channel Partner are adequately maintained.
• Categorise High-Risk Jurisdiction Clients.
• Conduct Periodic Reviews.



Under the UAE Federal Law No. 20 of 2018; and Cabinet Decision No. 10 of 2019. Companies depending on the nature and business of their Companies must ensure:

• The AML Policy and Procedures Manual must be maintained and is up to date.
• Any Suspicious Transactions Reports must be filed on the GoAML Portal.
• Any AML breaches must be reported.
• Staff needs to be trained, and AML workshops must be carried.


AML Risk Factors:


Country of Incorporation/ Registration

Country of Operations/Residence

Customer Type (Individual / Company / Foundation / Trust)

Customer’s Main Business: Activity / Industry

Customer Face-to-Face Meeting

Trading, Products & Nature of Services Offered

Ownership/Control (PEP Risk)

Proliferation Risk

Customer Introduction

Tax Crime Risk

Reputational Risk

Business Risk Assessment (from latest assessment)

KYC Documents – Company:
• Certificate of incorporation
• Business Profile
• Commercial License
• Share Certificate(s)
• Audited financial statements for the last 3 years
• Good Standing letter by the bank
• Police Report on the Shareholders (If important)

KYC Documents – Individual
• Identity Document
• Address Proof
• CV Profile
• Bank Reference Letter
• Bank Statement (If important)
• Proof of Company Ownership
• Letter from Auditor