These Guidelines are organized into five (5) parts, roughly corresponding to the following major themes:

Part I—Overview (including background information on the UAE’s AML/CFT legislative and strategy framework, and highlights of key provisions of the law and regulations affecting Financial Institutions);

Part II—Identification and Assessment of ML/FT Risks;

Part III—Mitigation of ML/FT Risks;

Part IV—AML/CFT Compliance Administration and Reporting (including guidance on governance, suspicious transaction reporting, and record-keeping);

Part V—Appendices.

The various sections and sub-sections of each part are organized according to subject matter. In general, each section or subsection includes references to the articles of the AML-CFT Law and/or the AML-CFT Decision to which it pertains. While it has been kept to a minimum, users may find that there are instances of repetition of some content throughout various sections of the Guidelines. This has been done in order to ensure that each section or sub-section pertaining to a specific subject matter is comprehensive, and to minimize the need for cross-referencing between sections.

In some cases, the requirements or provisions of specific sections of the relevant legal and regulatory frameworks are deemed sufficiently clear with regard to the statutory obligations of supervised institutions such that no additional guidance on those sections is provided for in these Guidelines. In other cases, guidance is provided with regard to subjects which are not covered explicitly in the AML-CFT Law or the AML-CFT Decision, but which are nevertheless addressed either implicitly or by reference to international best practices.

In certain instances in which there are meaningful differences between the relevant legal and regulatory framework currently in force and previous laws or regulations, or in which there are differences in specific regulatory requirements between various Supervisory Authorities, the Guidelines may or may not highlight these differences. In the event of such differences or discrepancies, supervised institutions seeking further clarification on matters related to those sections are invited to contact their relevant Supervisory Authority through the established channels.

It is the Supervisory Authorities’ intention to update or amend these Guidelines from time to time, as and when it is deemed appropriate. Supervised institutions are reminded that these Guidelines are not the only source of guidance on the assessment and management of ML/FT risk, and that other bodies, including international organisations such as FATF,

MENAFATF and other FATF-style regional bodies (FSRBs), the Egmont Group, and others also publish information that may be helpful to them in carrying out their statutory obligations. It is the sole responsibility of supervised institutions to keep apprised and updated at all times regarding the ML/FT risks to which they are exposed, and to maintain appropriate risk identification, assessment, and mitigation programmes, and to ensure their responsible officers, managers and employees are adequately informed and trained on the relevant policies, processes, and procedures.

Text from the AML-CFT and the AML-CFT Decision are quoted, or otherwise summarized or paraphrased, from time to time throughout these Guidelines. For the sake of convenience, unless specifically noted to the contrary, all references in the text to the term “financing of terrorism” also encompass the financing of illegal organisations. In general, capitalized terms in the text of these Guidelines have the meanings provided in the Glossary of Terms (see Appendix 11.1). However, in the event of any inconsistency or discrepancy between the text or definitions provided for in the Law and/or the Cabinet Decision and such quotations, summaries or paraphrases, or such defined terms, the former shall prevail.