As required by Article 7 of the AML-CFT Decision, LFIs must continuously monitor all their transactions to ensure that the transactions conducted are consistent with the information they have about the customer, their type of activity and the risks they pose, including, when necessary, the source of funds. As with all customer types, LFIs that use automated monitoring systems should apply rules with appropriate thresholds and parameters that are designed to detect common typologies for illicit behaviour. When monitoring and evaluating transactions, the LFI should take into account all information that it has collected as part of CDD.

Monitoring systems can include manual monitoring processes and the use of automated and intelligence led monitoring systems. In all cases, the appropriate type and degree of monitoring should appropriately match the money laundering and financing of terrorism (ML/FT) risks of the institution’s customers, products and services, delivery channels, and geographic exposure, and may therefore vary across an LFI’s business lines or units, where applicable. TM programs should also be calibrated to the size, nature, and complexity of each institution. The transaction monitoring system used by LFIs should be equipped to identify patterns of activity that appear unusual and potentially suspicious for PEPs customers as well as unusual behaviour that may indicate that a customer’s business has changed in such a way as to require a high risk rating. Please consult also the CBUAE’s Guidance for Licensed Financial Institutions on Transaction Monitoring and Sanctions Screening³ for further information.

³ Available at: https://www.centralbank.ae/en/cbuae-amlcft