3.3.2 Customer Due Diligence for Natural Persons

Effective from 15/8/2021

Article 4 of Circular No. 24/2019 requires RHP to identify and verify the identity of their customers, including remitters and beneficiaries, by using Emirates ID, or passport when Emirates ID is not available. RHP must collect at least the following information for each customer:

		•	Name,
		•	Emirates ID number or passport number when Emirates ID is not available;
		•	Date of birth and nationality;
		•	Address;
		•	Mobile number;
		•	Occupation; and
		•	The name of the person from whom the customer is receiving money, or the person to whom the customer is sending money and their country.

This information must be printed on customer receipts. RHP must record this information and store it in their files for five years. RHP must also take a clear photo or photocopy of the customer's identification document and retain it for five years.

The CDD process should also be applied when it appears that a natural person may be deliberately splitting up a larger transfer to evade the CDD requirement (for example by repeatedly once in a week transfer value below AED 3,500 per transaction).

Using this information, as discussed in Part II section 1 above on sanctions obligations, RHP should screen their customers, including the sender/beneficiary as appropriate, and the transaction against the UN Consolidated List and the Local UAE Terrorist List. Screening must be performed before carrying out any transaction for the customer. If there is a match, the RHP should carefully consider whether the other data collected (date of birth, country of birth) match the information available for the listed person in question. The RHP may continue with the transaction only if it is confident that its customer or the person on the other end of the transaction is not a listed person. In addition, if the RHP discovers that any party to the transaction is listed on the UN Consolidated List and the Local Terrorist List, it must not return the customer's funds or provide the customer with funds that have been sent to him, but must instead freeze the funds.

Furthemore, RHP should obtain a clear understanding of the intended purpose and nature of the transaction and ensure that it does not breach the permitted services by RHP listed in Part I section 4 above. RHP should consider whether it is consistent with what they know about the customer. Some examples of transactions that may require further investigation include:

	•	A customer who says he works as a labourer wishes to transfer a sum that is greater than the average yearly income for someone in his position.
	•	A customer visits the RHP on a regular basis and makes small or moderate-sized transfers, but the sum of the amounts he transfers over the course of the year is greater than the yearly income for someone in his position.
	•	A customer says that he has no occupation, but continues to make transfers or transfers a large sum.
	•	A customer who is from country A states that he is sending funds to a family member, but the beneficiary is located in country B.
	•	A customer from country A makes regular transfers to people he says are family members in that country, but they appear to live in different regions of country A and their relationship to the customer is not clear.

These transactions are not necessarily illicit, but they suggest that the RHP needs to collect additional information. For example, a customer may actually be acting on behalf of a business. In that case, the RHP's customer is actually the business, and it must perform CDD on the business as described in section 3.3.3 below. If the RHP has any additional concerns, it should follow the EDD procedures discussed in section 3.3.4 below.

RHP must cease and reject any transaction if they cannot collect any of the information required above, or if they cannot comply with any of the above requirements.