6.2.2 Occasional Transactions

Effective from 13/7/2023

During the course of business, FIs may be called upon to perform occasional or non-recurring transactions for customers with whom there is no ongoing account or Business Relationship. Examples of such transactions include, but are not limited to:

•	Exchange of currencies;
•	Issue or cashing/redemption of traveler’s cheques;
•	Transfer of money or other value for a walk-in customer;

On such occasions, and other than in the exceptional circumstances described below (see Section 6.2.3, Exceptional Circumstances), FIs are required to identify the customer and verify the customer’s identity as well as that of the Beneficial Owners, beneficiaries, and controlling persons. Furthermore, FIs are required to undertake appropriate risk-based CDD measures (see Section 6.3, Customer Due Diligence (CDD) Measures, Section 6.4, Enhanced Due Diligence (EDD) Measures, and Section 6.5, Simplified Due Diligence (SDD) Measures for further guidance), including among other things understanding the nature of the customer’s business and the purpose of the transaction, in the cases specified in Article 6 of the AML-CFT Decision, as follows:

•	When carrying out occasional transactions in favour of a Customer for amounts equal to or exceeding AED 55,000 (or equivalent in any other currency), whether the transaction is carried out in a single transaction or in several transactions that appear to be linked;
•	When carrying out occasional transactions in the form of Wire Transfers for amounts equal to or exceeding AED 3,500 (or equivalent in any other currency) (see Section 6.3.2, CDD Requirements Concerning Wire Transfers);
•	When there is a ML/FT suspicion (see Section 7.2, Identification of Suspicious Transactions);
•	When there are doubts about the veracity or adequacy of identification data previously obtained with regard to the customer.

Some of the indicators of transactions that may appear to be linked include, but are not limited to the following:

-	Multiple transactions with the same or similar customer reference codes;
-	Transactions executed sequentially or in close time proximity, and involving the same or related counterparties;
-	Multiple transactions attempted by a customer with whom there is no Business Relationship at different branches of the same FI on the same day.