AML Compliance Calendar
AML Compliance Calendar 2025
The AML regulations in the UAE impose many compliance obligations on Designated Non-Financial Businesses and Professions (DNFBPs). Keeping track of all the compliance processes for timely compliance can sometimes be challenging. Now, with AML UAE’s AML Compliance Calendar, manage your overall AML compliance journey with proper planning and do not stand a chance to miss any deadline.
Some requirements are ongoing or event-specific, requiring immediate attention, while some are annual and have a timeline prescribed to fulfil the compliance obligation. Here is the table depicting the primary AML obligations of DNFBPs, timelines and the AML Compliance Calendar’s tips on how to avoid non-compliance penalties:
Mapping of AML Obligations with AML Compliance Calendar
|
AML Obligation |
Timelines |
AML Compliance Calendar’s Tips |
|
Customer Due Diligence |
Before Onboarding a New Customer or Executing a Transaction |
Do not neglect CDD! Set up daily notifications at the end of the day to check if CDD processes, including screening, were performed during the onboarding or at the time of executing the transaction undertaken during the day. |
|
Transaction Monitoring |
Ongoing Basis |
Identify suspicious patterns! Set daily reminders at the beginning of the day to follow the ongoing transaction monitoring process before executing a transaction with an existing customer. |
|
Compliance Officer’s AML Report |
Semi-Annual Basis |
Let senior management be aware of the AML compliance efforts! Set up reminders for the Compliance Officer’s timely preparation and submission of periodic AML reports to the senior management. |
|
Reviewing CDD Details |
For High-Risk Customers: Semi-Annual Basis
For Medium and Low-Risk Customers: Annual Basis |
Keep your CDD records updated! Ensure that the Customer’s Risk Profiles are up-to-date. Undertake CDD reviews based on the customer’s risk category and ensure that you stay on top of the customer’s profile. |
|
AML Training |
Monthly Basis |
Promote a strong AML compliance culture! Schedule periodic training sessions for your employees and staff members. |
|
Independent AML Audit |
Annually |
Get your AML framework validated! Be sure to include the Independent Audit function as a part of your AML policy. Set up annual reminders for appointing a proficient independent person to review the AML program’s efficiency and quality. |
|
Annual AML Return Filing |
Annually For ADGM Units: Before April (For the reporting period of January to December)
For DIFC Units: Before September (For the period of August of the previous year to July of the reporting year) |
Let’s commit to timely AML submissions! Set advance notifications for compliance with regulatory expectations. |
|
Review and Update ML/FT/PF Enterprise-Wide Risk Assessment |
Annually or upon change in risk parameters |
Stay updated about your business’s ML/FT risks! Set annual notification highlighting your to-do to review your last ML/FT/PF Enterprise-Wide Risk Assessment and update it in line with revised ML/FT risk exposure. |
|
Updating AML Framework, including ML/FT/PF red flags |
Annually or upon a change in regulatory requirements |
Stay on the right side of the law! Stay tuned the regulatory updates and insights, to uncover the developing trends and typologies impacting the financial crime risk exposure. |
|
Annual AML/CFT Risk Assessment Report |
Annually |
Staying vigilant is the ultimate best practice! Track the notifications from the authorities for timely collating the data and completing the Annual AML/CFT Risk Assessment report. |
|
Modify the AML program as per the updated FATF Greylist |
As and when the FATF Greylist is updated (generally, in February, June, and October) |
Keep your AML compliance function dynamic! Set notifications to align your ML/FT/PF risk assessment and the overall AML program as per FATF’s updated Greylist. |
|
Reviewing the Clients’ Activeness Status |
Semi-annually |
Organise your client list from time to time! As part of the cleansing exercise, review the customer and supplier database to maintain an updated list with active entries, subject to regular AML compliance. |
|
goAML Reporting |
Event-based |
Promptly report suspicious activities! Keep track of the business relationship triggering the reporting of customers or transactions with the FIU. |
|
Any additional requirements from the Supervisory Authority |
As and when issued |
Forget the fear of missing out! Do not fear the unknown with AML UAE by your side! |
Significance of following AML Compliance Calendar 2025
- Perform adequate Customer Due Diligence (CDD) process for your customers, suppliers and third parties with whom you transact. These CDD measures consist of identifying the customers (through the Know Your Customer (KYC) form), screening and risk profiling the customer. The CDD measures are to be applied before establishing a business relationship with the customer/supplier or executing a transaction in case of an occasional customer.
- Risk mitigation measures are incomplete unless the customer’s transactions are monitored regularly. The AML laws require the DNFBPs to implement an ongoing transaction monitoring program to identify any unusual activity or pattern of transaction contradictory to the customer’s expected profile.
- To ensure that the senior management of the DNFBP is aligned with the ongoing activities around the AML framework, the laws mandate the Compliance Officers to furnish a periodic AML Report to the senior management. The Compliance Officer’s AML Report must include the following:
- Statistics around customer’s risk profile and CDD measures applied
- Information about reporting done with the Financial Intelligence Unit
- Any additional resources required in the company for managing the AML compliance framework
- Any new ML/FT red flags observed
- Suggestions or comments from the AML auditor, etc.
- DNFBPs must always keep the information about the customer updated. Thus, the Customer Due Diligence review program should be deployed to ensure the relevance and validity of the CDD profiles. DNFBPs must frequently review the customer’s due diligence, including the risk profile for customers classified as “high-risk”. For low and medium-risk customers, a less frequent monitoring process can be implemented.
- AML Training is necessary for every DNFBP – for the Compliance Officer, staff, and senior management to ensure effective implementation of the AML framework across the company. Training programs must be developed considering the significance of AML awareness amongst all employees and role-specific learning needs.
- AML laws mandate the implementation of an independent AML Audit function to check the efficiency and quality of the AML framework. The DNFBP’s AML Policy generally dictates the frequency and extent of AML audits, depending on the nature & size of DNFBP’s business operations, ML/FT/PF Enterprise-Wide Risk Assessment, etc.
- Financial Services Regulatory Authority (FSRA) and Dubai Financial Services Authority (DFSA) require the DNFBPs operating in ADGM and DIFC to file an annual AML return detailing the company’s AML compliance status and activities undertaken during 12 months.
- Assessing the AML business risk is essential to understanding the DNFBP’s vulnerability to ML/FT risk and designing the AML policies, procedures, and controls accordingly. The risk parameters may keep on changing with the company’s evolving business. Accordingly, DNFBPs must review and update the ML/FT/PF Enterprise-Wide Risk Assessment at least once a year or upon a material change in the significant risk factor.
- DNFBPs must maintain their AML/CFT Policies, Procedures, and Controls updated with the regulatory amendments, changes in the company’s business activities, and ML/FT Enterprise-Wide Risk Assessment. DNFBPs should update their AML Compliance framework at least once a year or upon significant changes in the AML regulations, business operations or ML/FT risk parameters.
- The Financial Intelligence Unit requires the DNFBPs to file a relevant report on the goAML portal in case of identification of any suspicious transaction or suspicious activity or where a confirmed or partial match is found with the Sanctions List or for specified transactions such as REAR or DPMSR. DNFBPs must comply with the following goAML reporting requirements:
- Regulatory authorities in UAE require DNFBPs to fill up a survey questionnaire as a part of their AML/CFT Annual Risk Assessment Report. Proper tracking of regulatory notifications and timely submission of the report is important for DNFBPs to stay compliant with regulatory expectations.
- As a part of the AML framework update, and even otherwise, it is important for DNFBPs to be tuned with the latest ML/FT/PF patterns and typologies and their red flags to combat evolving risks.
- To streamline their AML efforts, it is also important for DNFBPs to periodically assess the activeness status of their clients and suppliers. A general segregation of the active clients from the inactive or dormant clients can be helpful in diverting the AML compliance resources to the right place.
- The Financial Action Task Force is a global watchdog fighting ML/FT/PF activities. The greylist and blacklist published by the FATF is generally updated thrice a year and should be used as a guiding light for DNFBPs in aligning their AML compliance functions with global standards.
Apart from the above routine AML compliance tasks, the DNFBPs must ensure that it is registered with the goAML Portal and has its details up-to-date on the portal, including the appointment of the duly competent AML Compliance Officer.
Sync the AML Compliance Calendar with your Outlook or Gmail account and get timely notifications to achieve your AML compliance obligations.
Stay updated, stay compliant and avoid any non-compliance penalties.