3 AML/CFT Program

The AML/CFT Program and the Compliance Officer. This part discusses the content of the AML/CFT program and how it should be implemented by the RHP.

Understanding Risks. This section discusses how to identify the RHP's ML/TF risks so that the RHP can build an appropriate AML/CFT program.

Customer Due Diligence. This section discusses the mandatory procedures for identifying and understanding the RHP's customers and counterparties.

Record Keeping. This section discusses the records of activity that the RHP must maintain and provide to law enforcement authorities and counterparties.

يسري تنفيذه من تاريخ 15/8/2021

As per Articles 4, 20, 21 and 26 of the AML-CFT Decision, RHP are required to establish and maintain effective AML/CFT compliance programs designed to prevent them from being misused to facilitate money laundering or terrorist financing (ML/TF). The program must be risk-based and appropriate to the risk of the RHP, taking into consideration its:

		•	Size;
		•	Volume of transactions;
		•	Types of remittances offered (personal only or personal and commercial);
		•	Complexity;
		•	The nature and volume of its Hawala Activity;
		•	The nature of its customer base; and
		•	The geographic areas in which it operates.

This means that where an RHP engages in higher-risk activities (as discussed below in section 3.2), or does a higher volume of business, it must have a more sophisticated AML/CFT program and employ more intensive measures to manage this risk. The section that follows discusses the mandatory minimum elements of an AML/CFT program under the legal and regulatory framework in the UAE as well as ways that RHP can make adjustments to respond to their risk. It is divided into four parts, as follows: