3.3.4 Enhanced Due Diligence

Effective from 15/8/2021

Sometimes CDD alone as described above is not sufficient to fully understand a customer. In addition, for certain customers, an extra level of due diligence is required. In those cases, the RHP must perform EDD in the following circumstances:

	1.	The customer is a legal person. In these cases, the RHP must perform all the steps listed in section 3.3.3 above, plus additional due diligence as described here.
	2.	The customer is a natural person carrying out a transfer worth AED 55,000 or above. In those cases, the RHP must perform all the steps listed in section 3.3.2 above, plus additional due diligence as described in this section below.
	3.	The customer is a politically exposed person. During CDD, the RHP must collect information regarding the occupation of a natural person customer, and the beneficial owners of a legal person customer. If the customer, or the beneficial owners of a legal person customer, indicates that he or she is a government official with any government, the RHP must ask additional questions to understand that individual's rank and status. If the individual holds a high-ranking position in any government, then EDD is required for the customer. This is to make sure that the funds involved are not related to corruption or abuse of the customer's position.
	4.	The customer is from, or is sending a remittance to, a high-risk jurisdiction. As discussed in section 3.2 above, high-risk jurisdictions are those with a higher risk of ML/TF.

RHP should consider performing EDD when there are other high risks associated with the transaction, such as concerns about the customer's behaviour or about the source of the funds involved in the transaction.

When performing EDD, RHP must follow the following mandatory steps:

		•	Seek approval from the manager of the RHP to carry out the transaction. If the RHP is owned and operated by a single person, this step is not necessary.
		•	Collect additional information to understand the source of funds involved in the transaction and the customer's overall source of funds (i.e. source of wealth). For instance, the RHP may ask for a pay slip to verify the customer's income.
		•	Collect additional information about the customer's business. For example, if a transaction is linked to the sale of goods, the RHP may request to see the invoice.