An AML/CFT policy is the foundational document of a business's AML compliance programme, setting out the company's approach to risk assessment, customer due diligence, ongoing monitoring, suspicious transaction reporting and staff training. Under UAE AML regulations, every business subject to AML obligations is required to have a written AML/CFT policy and accompanying standard operating procedures that are approved by senior management, implemented across the business and reviewed regularly.
CashLaw Global develops AML/CFT policies and standard operating procedures for UAE businesses that are proportionate to the business's risk profile, compliant with UAE regulatory requirements and, critically, operationally implementable by the team that will be expected to follow them. We begin with a risk assessment of the business's customer base, product and service offering, geographic exposure and delivery channels. The policy and SOPs are then built around that risk assessment, covering CDD procedures, enhanced due diligence triggers, transaction monitoring rules, STR escalation procedures and staff training requirements.
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Book Free ConsultationA comprehensive manual must include a clear corporate Risk Assessment framework, structured Know Your Customer (KYC) and Customer Due Diligence (CDD) protocols, defined processes for enhanced due diligence (EDD) on high-risk profiles, established reporting procedures for suspicious transactions, and scheduled staff training plans.
We take international frameworks and customize them to align with UAE Federal Decree-Law No. (20) of 2018, integrating local requirements like mandatory daily reviews of the UAE Local Terrorist List and the Cabinet's targeted financial sanctions database.
While executive management is accountable for the overall compliance culture, the day-to-day enforcement, monitoring, and file review responsibilities rest with your officially appointed and qualified Money Laundering Reporting Officer (MLRO).