What Has Been Updated?
Based on the latest AML compliance requirements issued by MOET, the UAE Ministry of Economy & Tourism (MOET) has updated the requirements relating to High-Risk Jurisdictions and jurisdictions subject to Increased Monitoring.
The update is intended to further align with the latest FATF jurisdiction lists and international AML/CFT standards, and applies to relevant businesses within MOET’s supervisory scope.
01 Who Should Pay Attention?
The update specifically applies to the following sectors:
- Real estate brokers and agents;
- Dealers in precious metals and precious stones;
- Auditing or accounting firms; and
- Corporate Service Providers.
Businesses within these sectors should review whether their existing AML/CFT policies, customer due diligence procedures and risk assessment frameworks remain aligned with the latest requirements.
02 What Should Businesses Review?
Relevant DNFBPs should continue to monitor the latest jurisdiction lists and related information published by FATF and the relevant UAE authorities, and incorporate relevant updates into their risk assessments, customer due diligence processes and other applicable AML/CFT risk-management measures.
01 Business Relationships Involving High-Risk Jurisdictions
For business relationships or transactions involving jurisdictions identified by FATF as “High-Risk Jurisdictions subject to a Call for Action”, relevant DNFBPs should apply Enhanced Due Diligence (“EDD”) and other appropriate risk-mitigation measures in accordance with applicable regulatory requirements and the relevant risk assessment.
Such reviews may involve:
- Customers;
- Ultimate Beneficial Owners (UBOs);
- Legal entities;
- Counterparties;
- Persons acting on behalf of customers or entities; and
- Source of funds and other relevant transaction-related risk factors.
02 Internal Monitoring and Suspicious Transaction Reporting
Relevant DNFBPs should also maintain appropriate internal monitoring and reporting procedures and, where necessary, submit Suspicious Transaction Reports through the applicable FIU / goAML reporting mechanism.
The requirements also clarify that:
- Reliance on third parties located in FATF-listed High-Risk Jurisdictions to perform customer due diligence is not permitted; and
- Businesses should continue to comply with applicable Targeted Financial Sanctions (“TFS”) requirements.
03 CA Reminder
Following this update, businesses may wish to review their existing:
- Country and jurisdiction risk assessments;
- KYC / CDD procedures;
- Customer and UBO screening;
- Transaction monitoring;
- Source-of-funds review; and
- Internal escalation and reporting procedures.
Where a customer, UBO, counterparty, source of funds or transaction has links to a higher-risk jurisdiction, the appropriate level of due diligence should be assessed based on the specific circumstances and risk profile.
As jurisdiction classifications may be updated from time to time, businesses are encouraged to refer to the latest FATF publications rather than relying solely on previously downloaded or circulated lists.
CA can assist businesses in understanding the latest UAE regulatory developments and coordinating relevant AML/CFT compliance requirements based on their business activities and risk profile.
Official References
For the latest jurisdiction lists, please refer to the FATF official publications below:
Jurisdictions under Increased Monitoring
Grey List
High-Risk Jurisdictions subject to a Call for Action
Black List
Contact Us
For further information or support regarding UAE AML/CFT compliance requirements, please feel free to contact CA.