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AML Compliance for DPMS in the UAE



  1. Legal Framework:

    DPMS are categorized as Designated Non-Financial Businesses and Professions (DNFBPs) under UAE Cabinet Decision No. (10) of 2019. Compliance is required for monetary transactions equal to or exceeding AED 55,000.
  2. Key AML Obligations:
    • Risk Assessment: Identify and assess money laundering (ML) and terrorist financing (TF) risks.
    • Policies and Procedures: Establish and update AML/CFT policies to mitigate risks.
    • Customer Due Diligence (CDD): Conduct due diligence on customers, focusing on risk-based approaches.
    • Suspicious Transaction Reporting (STR): Report any suspicious activities to authorities.
    • Governance Framework: Appoint an AML Compliance Officer, ensure staff training, and implement internal controls.
    • Record Keeping: Maintain detailed records of transactions and business relationships.
    • Compliance with UN Sanctions: Adhere to directives on international sanctions and financial crime suppression.
  1. Special Risk Considerations:
    • High-value, portable, and cash-based transactions make DPMS vulnerable to ML/TF.
    • Transactions must be analyzed for patterns or structuring to avoid detection.
    • Geographical risks, such as sourcing from high-risk regions or conflict zones.
  2. Implementation Requirements:
    • Screen customers against sanctions lists and perform background checks.
    • Monitor ongoing transactions, especially high-risk customers or unusual patterns.
    • Verify beneficial ownership, especially in complex transactions.
    • Comply with additional risk-based requirements during supply chain stages.
  3. Training and Awareness:
    • Regular staff training on AML/CFT risks, red flags, and compliance measures.
    • Awareness of evolving typologies and techniques for ML/TF.
  4. Penalties for Non-Compliance: Non-compliance can result in penalties, including fines, business restrictions, and reputational damage.
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