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A guide for identifying customers and recording transactions in the UAE

Cabinet Decision No. (10) of 2019 stipulates that financial institutions (FIs) and non-financial businesses & professions (DNFBPs) must maintain proper records to ensure compliance with Anti-Money Laundering and Combatting Financing of Terrorism (AML-CFT). Financial institutions and debt collection agencies are required to keep records of all financial transactions, international commercial transactions, and cash transactions on a local and international basis.

In addition, the AML-CFT records must be kept for a minimum of five years following the completion of the transaction or termination of the business relationship with the Customer. Failure to comply will result in heavy fines. Consulting with a local AML consultant can help you comply. Continue reading to learn how to comply.  

Document Types to be Maintained

Companies in the UAE need to know what types of records they must maintain in order to ensure AML compliance. Obviously, their requirements will differ. However, it is critical that the FIs and DNFBPs adhere to the requirements related to the scanning, screening, and verification processes. Here is a list of some of the records companies must maintain:

  • Customer information
  • Transaction records
  • Annual MLRO reports
  • External & internal suspicion reports
  • Investigation records
  • Information not yet processed
  • Actions are taken following request from an authority
  • AML training registers

Keep the following records for AML compliance in the UAE

In order of priority, the following records should be reviewed:

Data about customers

In order to comply with AML obligations, companies are required to verify the customer’s identity and maintain copies of references, documents, and other relevant evidence. Additionally, CDD documents such as copies of identities and any other additional information must be maintained. If needed, these documents may be presented to the authorities. Dubai’s AML experts can help you stay in compliance with the law. 

Business transactions

Business relationships and transactions from the last five years are required to be maintained by companies with AML obligations. You must keep transaction records, such as credit and debit notes, and correspondence. For more clarity on this requirement, consult AML compliance advisers in Dubai.

Suspicion reports both internally and externally

It is the responsibility of the FIs and DNFBPs to comply with all internal and external reporting requirements, including keeping records of the transactions. Records of MLRO reviews must be maintained by your company. AML/CFT controls must be adhered to by the MLR/AML compliance officer. It is the responsibility of the companies to handle all information and check all suspicious cases of money laundering, revealing these to law enforcement.

How do I keep track of my customer's identity and transactions?

Keeping records is governed by local and international regulatory requirements. The following are some techniques for recording:

  • Maintain original documents
  • Maintain photocopies of original documents
  • Keep scanned copies of documents
  • Store the documents in electronic form
  • Store the documents on microfiche

What are the best ways to safely store AML-CFT records?

Keeping the records accessible is essential. Keeping records safely is critical as the company scales or expands. To facilitate mergers and acquisitions, you must develop an effective plan. Records must be kept in accordance with the guidelines. To ensure easy retrieval of the records, you must keep them in a place where they can easily be accessed. 

Penalties related to record-keeping

Companies that fail to create records on their financial transactions with customers will be penalized by AED 100,000. Financial transaction records and relevant documents are required to be stored for at least five years from the completion of the transaction or the expiry of the business relationship with the customer, or both.

Why should you hire Alya Auditors?

Dubai’s Alya Auditors is a leading provider of AML services. Our AML solutions ensure compliance for FIs and DNFBPs. In addition to building an AML-CFT framework, we provide AML training, and AML-CFT penalty appeal services.