Annual goAML System Readiness and TFS Compliance Checklist for DNFBPs

Annual goAML System Readiness and TFS Compliance Checklist for DNFBPs

Annual goAML System Readiness and TFS Compliance Checklist for DNFBPs

Annual goAML System Readiness and TFS Compliance Checklist for DNFBPs

Any DNFBP’s AML/CFT Compliance framework’s robustness hinges entirely upon their system readiness and regulatory reporting precision. AML/CFT Compliance landscape in UAE requires DNFBPs to have flawless internal systems and controls to meet regulatory reporting requirements, including Targeted Financial Sanctions (TFS) compliance requirements through the goAML portal.

This is why every DNFBP must conduct a comprehensive Annual goAML System Readiness and & TFS Compliance audit. DNFBPs must have verifiable controls as mandated by the FIU and the Executive Office for Control and Non-Proliferation (EOCN).

The Annual goAML System Readiness & TFS Compliance Checklist for DNFBPs can be used as an essential governance tool for identifying gaps or issues in a DNFBP’s goAML reporting and TFS compliance framework, as it helps to identify underlying gaps and blind-spots in a business’s goAML reporting procedures and TFS compliance measures, enabling the DNFBP to take corrective and timely action to remedy issues identified to ensure continuous AML/CFT and TFS compliance with sound goAML reporting procedures in place.

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UAE KYC Essentials: A Complete Guide to Regulatory Compliance

UAE KYC Essentials - A Complete Guide to Regulatory Compliance T

UAE KYC Essentials: A Complete Guide to Regulatory Compliance

Want to know how the Know Your Customer (KYC) process works in UAE?

Here’s a breakdown of everything you need to know about KYC fundamentals, from rules to real results. Master core KYC components in minutes.

In this video, we throw light on core essentials of KYC:

This session serves as a go-to guide to businesses for successful customer identification and verification.

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Checklist to Identify AML/CFT Programme Alignment with FATF Grey List Updates

Checklist to Identify AMLCFT Programme Alignment with FATF Grey List Updates

Checklist to Identify AML/CFT Programme Alignment with FATF Grey List Updates

Checklist to Identify AML/CFT Programme Alignment with FATF Grey List Updates

With the Financial Action Task Force (FATF) updating its “Grey List” or “Jurisdictions under increased monitoring” list thrice a year, it becomes vital for Regulated Entities in UAE to be prepared with the necessary actionable steps, processes, and workflows that can be triggered immediately upon revision, addition, and deletion to the FATF Grey List 

Each time FATF issues a Grey List update, Regulated Entities are required to recalibrate their: 

Our Checklist + RACI Matrix helps Regulated Entities to be prepared and armed with necessary measures as and when FATF issues new Grey List, with additions and deletions of countries, directly impacting the geographic risk component, that need to be modified and incorporated into the Regulated Entity’s AML/CFT Policies, Procedures, and Controls Documentation. 

Do not wait for the regulator’s next inspection to find a gap pertaining to FATF Grey List adherence in your AML/CFT Framework. Demonstrate proactive AML/CFT compliance by downloading and arming yourself with the Checklist to Identify AML/CFT Programme Alignment with FATF Grey List Updates. 

Why do Financial Institutions and DNFBPs need a dedicated FATF grey list alignment checklist?

The FATF conducts plenary meetings and updates its list of “jurisdictions under increased monitoring”, more popularly known as the grey list, several times a year. Each FATF plenary decides if a country needs to be added or removed from the grey list.

The AML programme of UAE DNFBPs and FIs must reflect the changes in jurisdictional risk profile to keep themselves compliant with AML/CFT laws, and CBUAE, MOECT, MoJ, VARA, FSRA, DFSA, and SCA rules and guidelines.

The FATF grey list compliance checklist provides DNFBPs and Fis with a clear and actionable roadmap to stay compliant and make necessary changes in the EWRA, CRA, EDD triggers, software configuration, jurisdictional risk, and AML/CFT procedures.

Who is this FATF grey list readiness checklist designed for in the UAE?

The FATF grey list readiness checklist is designed for financial institutions, VASPs, and DNFBPs in UAE. These reporting entities are supervised by CBUAE, VARA, MOECT, MoJ, SCA, DFSA, FSRA, and other authorities in UAE. The FATF grey list alignment checklist is relevant for:

  1. Banks, Financial Institutions
  2. Exchange Houses
  3. Insurance Companies
  4. Payment Service Providers
  5. Dealers in Precious Metals and Stones
  6. Trust and Company Service Providers
  7. Real Estate Agents and Brokers
  8. Lawyers, Notaries, and Other Legal Professionals
  9. Auditors and Accountants
  10. Virtual Asset Service Providers

The RACI chart provided in the FATF grey list alignment checklist defines who needs to do what and in what capacity. The grey list readiness checklist is helpful to the frontline staff, compliance team, auditors, and management.

What does the FATF grey list alignment checklist actually cover?

This checklist covers four core compliance obligations that need to be revised as and when the FATF grey list gets revised. 

  • Enterprise-Wide Risk Assessment (EWRA)  
  • Customer Risk Assessment (CRA) parameters 
  • Enhanced Due Diligence triggers and parameters 
  • AML/CFT Software and tools such as Sanctions Screening, CDD, CRA, etc. 

Further, the checklist also aids in confirming whether updates to these compliance obligations have been incorporated into the Regulated Entity’s AML/CFT Policies and Procedures Framework. 

How should UAE firms use this checklist when FATF updates the grey list?

This checklist can be used by Regulated Entities whenever FATF updates the grey list to carry out compliance updates in three phases, namely:  Phase 1: Impact Mapping 
  • Identifying which newly added or deleted countries are included in the: 
    • Regulated Entity’s customer base, including UBOs 
    • Regulated Entity’s correspondent banks and payment partners 
    • Regulated Entity’s transaction corridors and transport routes. 
  • Identifying which parts of AML/CFT procedures and controls are likely to be impacted using the checklist, for instance, CRA rules or parameters, ongoing monitoring scenarios, etc. 
Phase 2: Checklist Walk Through and Gap Catagorisation 
  • The compliance teams within Regulated Entities can go through the checklist and mark their current compliance and controls stance as: 
    • Aligned: Where existing control measures are in alignment with the revised grey list 
    • Partially Aligned: Where existing control measures are not completely aligned but require tweaks and adjustments for complete alignment with the latest grey list updates  
    • Not Aligned: Where there are no control measures to mitigate risks posed by the latest additions to the grey list. 
Phase 3: Update Completion Documentation and Sign-Off 
  • Compliance teams must ensure that for every item marked as “aligned” in the checklist, the Regulated Entity has in place the following documentation, such as:  
    • Revised AML/CFT Policies, Procedures, and Controls Framework 
    • AML Software Configuration logs with dates 
    • AML/CFT Training Records 
    • The compliance team must also prepare summarised reports for Senior Management and the Board, confirming the completion and conclusion of aligning AML control measures with the latest grey list updates. 

    How does the RACI matrix work with this grey list checklist?

    The RACI Matrix, forming part of this checklist, helps Regulated Entities define who is responsible, accountable, consulted and informed for which specific realignment and compliance mapping tasks. It helps in allocating roles and responsibilities across teams for better coordination and establishing seamless workflows that ensure task completion.  

    Typical RACI for Regulated Entities

    The RACI in this checklist helps distribute FATF Update recalibration responsibilities such as tracking FATF updates, revising EWRA, CRA and risk registers, conducting reKYC and EDD, revising AML/CFT Policies and Procedures, etc, across the following roles: 

    • Frontline Team  
    • KYC Analyst  
    • Screening Analyst  
    • Transaction Monitoring Analyst  
    • AML Compliance Officer/ MLRO 
    • Senior Management. 

    How often should UAE firms run this grey list alignment checklist

    Compliance teams of Regulated Entities must run this grey list alignment checklist every single time the FATF issues a fresh grey list update, typically this happens thrice a year. The checklist can be incorporated as a standard ML/FT risk mitigation measure rather than a one-time use checklist. 

    FAQ s about Checklist to Identify AML/CFT Programme Alignment with FATF Grey List Updates

    What is the purpose of this FATF grey list alignment checklist for UAE firms

    This checklist is designed to assist AML Compliance teams in navigating the obligation to update their AML/CFT Compliance Framework as and when the FATF issues the latest “jurisdictions under increased monitoring” or more commonly referred to as “Grey List” with ease, as the checklist helps Regulated Entities demonstrate to regulatory authorities that: 

    • They are equipped to track changes in the FATF grey list 
    • They have a documented, repeatable process to update their EWRA, CRA, reKYC, EDD, and AML Software configurations as and when the grey list gets updated 
    • They have clearly defined workflow procedures in place that helps allocate responsibilities across various, demonstrated through the RACI matrix that gets operational whenever FATF grey list is updated. 

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    Checklist to Identify Misuse of Corporate Structures to Strengthen AML/CFT Compliance

    Checklist to Identify Misuse of Corporate Structures to Strengthen AML-CFT Compliance

    Checklist to Identify Misuse of Corporate Structures to Strengthen AML/CFT Compliance

    Checklist to Identify Misuse of Corporate Structures to Strengthen AML/CFT Compliance  

    Corporate vehicles are widely used in today’s economy for legitimate business activity, but their complexity and cross-border activities’ lack of transparency can be exploited to hide ultimate owners and enable illicit funds transfer that finances terrorism and other crimes. For Regulated Entities, this poses a serious AML/CFT challenge while businesses benefit from a legitimate corporate structure. They must stay vigilant to detect and mitigate the misuse of these vehicles for Terrorism Financing.  

    Here is one-click-away, easily downloadable “Checklist to Identify of Misuse of Corporate Structures to Strengthen AML/CFT Compliance” + RACI Chart, designed to help you identify suspicious corporate structures, trace obscure ownership, detect anomalies, financial flows, and escalate cases efficiently. 

    So, if you are part of the customer onboarding team, KYC analyst, a screening analyst, an AML compliance, a Transaction Monitoring Analyst, a Senior Manager, or a Compliance enthusiast, you must be equipped with the right tools to identify red flags and take action.  

    • Identifying the effectiveness of control measures surrounding documents, customers, transactions and third-party or intermediaries to detect any red flags indicating concealment of funds. 
    • Recognising the concealment of funds through nominees, incomplete data or refusal to provide adequate ownership information. 
    • Identifying process efficiency for red flag indication around transactions, financial inconsistency, which might be associated with ML, TF and PF activities. 
    • Designing workflow, role clarity, task allocation and task escalation for managing cases with fund management abuse. 

    Download this “Checklist to Identify Misuse of Corporate Structures to Strengthen AML/CFT Compliance” today and align your business with AML/CFT regulations, while addressing real-world risks associated with the misuse of corporate vehicles. 

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    Updated list of FATF high-risk countries and countries under increased monitoring: 24th October 2025

    Pathik Shah

    Table of Contents

    Protect your business with reliable and effective AML strategies with AML UAE.

    FATF List of High Risk Countries

    In the latest plenary, which concluded on 24th October 2025, South Africa, Nigeria, Mozambique, and Burkina Faso were removed from the Grey List. The FATF Grey List is also known as the Jurisdiction under Increased Monitoring list. This list includes countries that are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. 

    The FATF is an international body that establishes intercontinental standards to combat money laundering, counter-terrorism financing and combat financing of proliferation of weapons of mass destruction, updates the list of jurisdictions under increased monitoring thrice annually. 

    List of Jurisdictions under Increased Monitoring (Grey List) as of 24th October 2025

    FATF Grey List and Blacklist Update History:

    Date 

    Countries Added

    Countries Removed
    Countries in grey list
    1. Angola
    2. Algeria
    3. Côte d’Ivoire 
    4. Lebanon
    1. Senegal
    1. 1. Angola 
    2. 2. Algeria 
    3. 3. Bulgaria 
    4. 4. Burkina Faso 
    5. 5. Cameroon 
    6. 6. Côte d’Ivoire 
    7. 7. Croatia 
    8. 8.Democratic Republic of the Congo 
    9. 9. Haiti 
    10. 10. Kenya 
    11. 11. Lebanon 
    12. 12. Mali 
    13. 13. Monaco 
    14. 14. Mozambique 
    15. 15. Namibia 
    16. 16. Nigeria 
    17. 17. Philippines 
    18. 18. South Africa 
    19. 19. South Sudan 
    20. 20. Syria 
    21. 21. Tanzania 
    22. 22. Venezuela 
    23. 23. Vietnam 
    24. 24. Yemen 

     

    1. Monaco
    2. Venezuela
    1. Jamaica
    2. Türkiye
    1. 1. Bulgaria 
      2. Burkina Faso 
      3. Cameroon 
      4. Croatia 
      5. Democratic Republic of the Congo 
      6. Haiti 
      7. Kenya 
      8. Mali 
      9. Monaco 
      10. Mozambique 
      11. Namibia 
      12. Nigeria 
      13. Philippines 
      14. Senegal 
      15. South Africa 
      16. South Sudan 
      17. Syria 
      18. Tanzania 
      19. Venezuela 
      20. Vietnam 
      21. Yemen 

     

    1. Kenya 
    2. Namibia

     

    1. Barbados
    2. Gibraltar Uganda 
    3. United Arab Emirates
    1. Bulgaria
    2. Burkina Faso
    3. Cameroon
    4. Democratic
    5. Republic of the Congo
    6. Croatia
    7. Haiti
    8. Jamaica
    9. Kenya
    10. Mali
    11. Mozambique
    12. Namibia
    13. Nigeria
    14. Philippines
    15. Senegal
    16. South Africa
    17. South Sudan
    18. Syria
    19. Tanzania
    20. Türkiye
    21. Vietnam
    22. Yemen

    1. Algeria
    2. Angola
    3. Bolivia
    4. Bulgaria
    5. Cameroon
    6. Côte d’Ivoire
    6. Democratic Republic of Congo
    8. Haiti
    9. Kenya
    10. Laos

    11. Lebanon
    12. Monaco

    13. Namibia
    14. Nepal
    15. South Sudan
    16. Syria
    17. Venezuela
    18. Vietnam
    19. Virgin Islands (UK)
    20. Yemen

    Jurisdictions under Increased Monitoring - Grey List

    Which publicly recognizes jurisdictions that have committed to, or are actively working with, the FATF to resolve strategic deficiencies in their anti-money laundering, combatting of terrorism financing as well as combatting of proliferation financing (AML/CFT/CPF) regimes within agreed timelines. This list is commonly known as the “grey list.”

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    FATF Grey List and Blacklist Update History:

    In the latest plenary, which concluded on 24th October 2025, South Africa, Nigeria, Mozambique and Burkina Faso were removed from the Financial Action Task Force (FATF) Grey List.

    In the last plenary, which concluded on 13thJune 2025, Croatia, Mali, and Tanzania are removed from the Financial Action Task Force (FATF) Grey List and

    • Bolivia
    • the Virgin Islands (UK)

    were added to grey list.

    In the plenary, that concluded on 21st  February 2025, Philippines was removed from the Financial Action Task Force (FATF) Grey List, and: 

    • Lao PDR
    • Nepal

    were added to the Grey List.

    In the plenary that concluded on 25th October 2024, Senegal was removed from the Financial Action Task Force (FATF) Grey List, and: 

    • Angola,
    • Algeria,
    • Côte d’Ivoire
    • Lebanon

    were added to the Grey List.

    In the plenary that concluded on 28th June 2024, Jamaica and Türkiye were removed from the FATF Grey List and:

    • Monaco
    • Venezuela

    were added to Grey List.

    In its plenary, which concluded on 23rd February 2024, the FATF removed UAE, Barbados, Gibraltar, and Uganda from the Grey List, whereas:

    • Kenya
    • Namibia

    were added to the Grey List.

    In October 2023, the, while the following countries were removed: Albania, Cayman Islands, Jordan. and Panama and:

    • Bulgaria

    was added to the Grey List.

    The FATF established two statements as part of its listing and monitoring procedures to assure consistency with its international standards.

    To learn more about the difference between FATF-blacklisted countries and greylisted countries: Checkout What are FATF Blacklist and Grey list countries? 

    No.CountryNo.Country
    1Bulgaria12Nigeria
    2Burkina Faso13Philippines
    3Cameroon14Senegal
    4Croatia15South Africa
    5Democratic Republic of the Congo16South Sudan
    6Haiti17Syria
    7Kenya18Tanzania
    8Mali19Venezuela
    9Monaco20Vietnam
    10Mozambique21Yemen
    11Namibia  

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    High-Risk Countries Subject to a Call for Action - FATF Blacklist

    FATF categorises certain countries as “Blacklist” countries. This “Blacklist” identifies jurisdictions with substantial strategic weaknesses publicly in their AML/CFT/CPF regimes and calls on all FATF members to conduct enhanced due diligence and, in the most severe cases, implement countermeasures to protect the international financial system from money laundering, funding of terrorism and proliferation risks stood by the identified nations. This list is commonly referred to as the “Blacklist.” 

    Recently, the FATF has added Myanmar to this list of High-Risk countries subject to a Call for Action. Accordingly, with effect from 21st October 2022, the FATF “Blacklist” stands as under

    • Iran and the Democratic People’s Republic of Korea (subject to FATF call on its members/jurisdictions to apply countermeasures),  
    • Myanmar (subject to FATF call on its members/jurisdictions to apply enhanced due diligence measures proportionate to the risks arising from Myanmar). 

    AML Compliance pertaining to grey-listed and blacklisted countries

    All Financial Institutions (FIs) and Designated Non-Finance Businesses and Professions (DNFBPs) are required to have appropriate risk-based AML/CFT protections in place to limit the potential of money laundering and terror financing posed by countries subject to increased monitoring or listed as high-risk jurisdictions subject to a “Call for Action” by FATF. 

    As a result, FI and DNFBPs must screen customers against the FATF Jurisdictions under Increased Monitoring and High-Risk Jurisdictions Subject to a Call for Action while onboarding and continuously monitor their transactions throughout their business relationship. DNFBPs should ensure that their customer due diligence measures verify their customer’s residence in, or business with, listed countries and that their transaction monitoring measures can examine the size, frequency, and pattern of transactions involving high-risk countries to determine the possibility of occurrence of financial crimes such as money laundering. 

    FIs and DNFBPs must file suspicious transaction/activity reports (STR/SAR) to the Financial Intelligence Unit (FIU) when red flags are observed so that enforcement actions can be conducted.  

    Further, FIs and DNFBPs are obligated to report the transaction or activity with high-risk countries subject to a “Call for Action” to the FIU by filing High-Risk Country Transaction Report or High-Risk Country Activity Report (HRC/HRCA), as the case may be

    Is Conducting a Re-KYC after the FATF Updates Too Cumbersome?

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    Role of AML UAE

    AML UAE is a leading AML compliance services provider in UAE. We help you with fulfilling all the requirements for AML and CFT in UAE. Our spectrum of AML compliance services is not restricted to national boundaries, but we also make sure that you comply with the global regulations of AML.

    We can help you with:
    • Creating firm-specific AML policies, procedures, internal controls, best practices, and guidelines for your smooth business operations
    • Setting up an expert AML compliance department for your firm that can handle all AML-related activities
    • Selecting the most effective and appropriate AML software for your business needs to ensure AML compliance
    • Helping you in filing and submitting annual AML/CFT risk assessment reports with the UAE government
    • Conducting training for your employees in handling KYC, screening, risk profiling, CDD, EDD, and filing of STRs

    High-Risk Countries - FAQs

    What is the significance of the FATF?

    Through its position in setting global standards to combat terrorist financing, assisting jurisdictions in implementing financial provisions of United Nations Security Council resolutions on terrorism, and evaluating countries’ ability to prevent, detect, investigate, and prosecute terrorist financing, the FATF plays a critical role in global efforts to combat terrorism financing. Despite this, several nations have yet to apply the FATF Standards fully. They are unaware of the nature of the TF threats they face and lack adequate counter-measures.

    When a regime is put on the Grey List by the FATF, it means the country is actively working with FATF to fight against money laundering and other risks. It means the government is taking active measures to identify the deficiencies in its regulatory structure and correct them within the agreed timelines.  

    FATF Blacklist features the high-risk jurisdictions subject to a Call for Action. As per the FATF October 2022 plenary report, the Democratic People’s Republic of Korea, Myanmar and Iran feature in the FATF Blacklist.  

    A member of the FATF may impose economic sanctions on a country on the blacklist. North Korea, Iran and Myanmar for example, are both on the FATF Blacklist. As a result, sanctions against North Korea, Iran and Myanmar are possible.

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    About the Author

    Pathik Shah

    FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)

    Pathik is an ACAMS-certified AML consultant specialising in governance, risk, and compliance for regulated entities in the UAE. He brings over 28 years of experience, with 1,000+ hours of AML training and 200+ advisory engagements across DNFBPs, VASPs, and FIs. He supports businesses in aligning with AML/CFT requirements from the CBUAE, DFSA, MoET, MoJ, VARA, CMA, FSRA, and FATF. Known for translating complex regulations into audit-ready procedures, Pathik enables operational clarity and compliance readiness.

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    South Africa, Nigeria, Mozambique, and Burkina Faso Off from FATF Grey List October 2025 Plenary

    South Africa, Nigeria, Mozambique, and Burkina Faso Off from FATF Grey List October 2025 Plenary

    South Africa, Nigeria, Mozambique, and Burkina Faso Off from FATF Grey List: October 2025 Plenary

    Executive Summary:

    • Removed from Grey list: 4 removals — South Africa, Nigeria, Mozambique, Burkina Faso.
    • Added to Grey List: No new additions.
    • Blacklist: No change.
    • Rationale: Progress on AML/CFT frameworks and inter-agency coordination.

    South Africa, Nigeria, Mozambique, and Burkina Faso Off from FATF Grey List: October 2025 Plenary

    As part of its mandate, FATF periodically provides updates for jurisdictions under their increased monitoring colloquially known as the “FATF Grey List”. This is a list of countries with strategic deficiencies in their AML/CFT/CPF regimes and are actively working with FATF to address these deficiencies.  

    On 24th October 2025, the last plenary session of the year was concluded by the FATF. It brought significant changes to the status of grey listed countries. South Africa, Nigeria, Mozambique, and Burkina Faso were removed from the FATF Grey List.  

    The Financial Action Task Force (FATF) is a global watchdog against the crimes of Money Laundering (ML), Terrorism Financing (TF), and Proliferation Financing (PF). FATF undertakes extensive research and sets international standards to combat financial crimes. FATF has issued uniform recommendations on Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT), and Counter-Proliferation of Financing (CPF), for countries. It diligently monitors the compliance of these norms in the domestic AML/CFT/CPF framework of countries around the globe. 

    Updates Made to the Financial Action Task Force (FATF) Grey List on 24th October 2025

    FATF Plenary October 2025: Updates made to FATF greylist mainly include removal of four countries as discussed below. 

    Countries Removed from FATF Grey List (Jurisdiction Under Increased Monitoring) on 24th October 2025:

    • FATF removes Burkina Faso from Grey List: 24th October 2025
    • FATF removes Mozambique from Grey List: 24th October 2025
    • FATF removes Nigeria from Grey List: 24th October 2025
    • FATF removes South Africa from Grey List: 24th October 2025

    The FATF Grey List as of 24th October 2025: FATF Jurisdictions Under Increased Monitoring as of 24th October 2025

    1. Algeria
    2. Angola
    3. Bolivia
    4. Bulgaria
    5. Cameroon
    6. Côte d’Ivoire
    6. Democratic Republic of Congo
    8. Haiti
    9. Kenya
    10. Laos

    11. Lebanon
    12. Monaco

    13.
    Namibia
    14.
    Nepal
    15.
    South Sudan
    16.
    Syria
    17. Venezuela

    18. Vietnam

    19.
    Virgin Islands (UK)
    20. Yemen

    Immediate impact of the FATF Grey List update 24th October 2025 on Regulated Entities:

    As a consequence of FATF Grey List October 2025 Update, AML Compliance measures implemented by Regulated Entities need to be revised:

    • Enterprise- Wide Risk Assessment (EWRA):
    • Customer Due Diligence (CDD): CDD measures concerning customers or suppliers associated with “FATF defined Jurisdictions Subject to Increased Monitoring”
    • AML Policies and Procedures:
    • Recalibrating configuration of AML software solutions

    To know more about how the FATF Grey List update triggers changes in a regulated entity’s AML/CFT/CPF compliance process, read our extensive blog on “Impact of FATF Grey List Update on UAE DNFBPs: AML/CFT Compliance Imperatives” 

    What will be the Implications of FATF Greylisting on the British Virgin Islands (BVI)?

    Due to the greylisting of British Virgin Islands (BVI) by FATF, the costs associated with financial transactions originating from and destined to BVI would increase. Further, the businesses would experience slight delays in the processing of transactions by banks as banks and financial institutions adopt a risk-based approach while dealing with high-risk jurisdictions like Virgin Islands (UK).

    The obligated entities will have to assess the BVI greylisting impact on its Enterprise-Wide ML/FT risk assessment, take a risk-based approach and align policies and procedures with the revised EWRA.

    The reporting entities would also need to change their internal processes in relation to transaction monitoring and customer risk assessment, consequent to the greylisting of BVI.

    Further, the BVI-based entities will have to adopt suitable measures to ensure that they have accurate beneficial ownership information about their clients.

    How Does Bolivia’s Inclusion on the FATF Grey List Countries 2025 Impact Its Virtual Asset Sector?

    The Virtual Asset Sector in Bolivia would be subjected to stringent ML/FT controls consequent to Bolivia’s greylisting by FATF on 13th June 2025. The government would try to bring in a stringent regulatory framework and stricter supervision of crypto exchanges and crypto assets wallet providers. The obligated entities will have to strengthen their CDD, transaction monitoring, and suspicious transaction monitoring-related controls and have a more comprehensive process for the ultimate beneficial owner identification.

    This would result in increased compliance costs for VASPs based out of Bolivia. Banks and financial institutions would adopt a risk-based approach and decide to go for de-risking the relationship.

    Due to Bolivia’s inclusion on the FATF Grey List countries 2025, the international businesses dealing with Bolivia in sectors like virtual assets, trade finance, money exchange, and precious metals and stones will reassess their risk, and the Bolivia-based businesses might have to undergo EDD measures.

    What Does Removal from the FATF Grey List Mean for Croatia?

    Consequent to the removal of Croatia from FATF’s grey list (the list of jurisdictions under increased monitoring), it would benefit Croatia’s economy, and Croatia’s financial institutions will have greater access to international correspondent banking and can resort to relaxed norms around customer due diligence.

    The international businesses dealing with Croatia will take a risk-based approach, and they will be exposed to lower compliance risks while dealing with Croatia-based entities. It would make transaction processing faster as there would be reduced customer diligence requirements, and it would improve investor confidence.

    Croatia’s successful removal from grey list shows its commitment to following a methodical, transparent, and sustained effort to comply with and implement FATF recommendations.

    Action Plan for Regulated Entities Consequent to Changes in Financial Action Task Force Grey List dated 24th October 2025

    – Conduct Enterprise-Wide Risk Assessment and assess the likelihood of ML/TF risks arising from the exposure to the latest FATF Grey List countries.  

    – Revise risk matrices to flag  

    • South Africa 
    • Nigeria  
    • Mozambique  
    • Burkina Faso  

    related profiles to appropriate risk ratings while considering other risk factors applicable. 

    – Ensure Enhanced Due Diligence (EDD) is applied to the customers or suppliers associated with the “FATF defined Jurisdictions subject to increased monitoring”.  

    – Update internal AML Policies and Procedures to reflect the material changes of FATF Grey List  

    – Recalibrate the configuration of AML software solutions in proportion with the FATF Grey List updates  

    – Ensure that screening and submission of Regulatory Reports capture elevated or diluted risks associated with the Grey-Listed countries and mandate escalation as per the updated list.  

    – Conduct structured training sessions for the employees to educate them with updated procedures for dealing with the customer.   

    Grey Lists Changes, Your Vigilance Shouldn’t

    AML UAE Helps You to Strengthen Your Compliance Requirements with Every FATF Update

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    Checklist for Recognising Disguising of Funds to Ensure Robust AML/CFT Compliance

    Checklist for Recognising Disguising of Funds to Ensure Robust AML-CFT Compliance

    Checklist for Recognising Disguising of Funds to Ensure Robust AML/CFT Compliance

    Checklist for Recognising Disguising of Funds to Ensure Robust AML/CFT Compliance

    It is necessary for Regulated Entities to analyse the movement of funds through Regulated Entities. Regulated Entity’s personnel such as a member of the customer onboarding team appointed as frontline staff, MLRO or transaction monitoring analysts, needs to assess, mitigate or report the risks related to movement and obscuring of funds through Regulated Entities. 

    Here is a ‘one-click away’ downloadable Checklist for Recognising Disguising of Funds to Ensure Robust AML/CFT Compliance + RACI matrix to ease your compliance work. This checklist includes: 

    • Identifying obscure fund movements across DNFBPs, VASPs, and FIs that may indicate ML/TF. 
    • Assessing control measures for document verification, customer profiling, and cross-border transactions to detect unusual patterns and layering. 
    • Implementing a RACI matrix to assign roles and responsibilities and escalation when suspicious activities arise. 
    • Strengthening regulatory compliance by aligning with FATF guidelines and domestic AML/CFT expectations. 

    Download this checklist for Recognising Disguising of Funds to Ensure robust AML/CFT compliance + RACI matrix, whether you are in Dubai or Abu Dhabi, to align your business with robust AML/CFT compliance. 

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    The KYC Lesson: How Mr Mysterious Met Granny Compliance in the World of AML

    The KYC Lesson - How Mr Mysterious Met Granny Compliance in the World of AML

    The KYC Lesson: How Mr Mysterious Met Granny Compliance in the World of AML

    The KYC Lesson: How Mr Mysterious Met Granny Compliance in the World of AML

    It was a sunny morning on Bankville Lane. The birds were chirping, the lawns were freshly mowed, and the neighbours were going about their usual routines. Mrs Whiskers was watering her tulips. Mr Potts was adjusting his telescope. Everything was peaceful and predictable, just as it should be.

    That is, until a van covered in glitter rolled onto the street.

    Out stepped a tall man wearing shiny purple boots, sunglasses, and a wide-brimmed hat covered in tiny bells. He dragged a suitcase behind him labelled: “BEANS”.

    “Hello, good people of Bankville!” he called out in a grand voice. “You may call me Mr Mysterious.”

    The neighbours peeked through the curtains.

    “I sell magic beans,” he announced proudly. “They help pigeons fly faster and make cupcakes sparkle.”

    A few neighbours smiled politely. Others were confused.

    Now, Bankville was a friendly place, but not a careless one. They didn’t let anyone in without getting to know them first, not after the Great Lawn Flamingo Incident in 2018.

    So, out came Granny Compliance.

    She was small and slouched, wore glasses on a chain, and carried a clipboard wherever she went. No one really knew how old she was, but everyone knew this: if anyone new showed up in Bankville, Granny Compliance would find out who they really were.

    “Welcome to Bankville, Mr Mysterious”, she said with a kind but serious tone. “Before you get settled, I need to ask you a few things.”

    “Is this a quiz?” he asked.

    “No,” she replied. “This is just a way we make sure we understand who we’re dealing with before we do business, bake sales, or block parties. This is KYC.”

    Mr Mysterious blinked. “But I’m charming.”

    “I’m sure you are,” Granny Compliance replied. “But charm isn’t an official form of identification.”

    She clicked her pen. “Let’s begin.”

    Step 1: Who Are You?

    “First things first,” she said. “What’s your real name, and do you have any documents to prove it?”

    Mr Mysterious handed her a business card that read:

    Mr Mysterious, CEO of Beans & Dreams Co.

    “Do you have an ID?” she asked.

    He pulled out a passport. It was real. Issued in the town of Squeezyville.

    “Good start,” she nodded.

    Step 2: What Do You Actually Do?

    “You said you sell magic beans. Do you have a license for that?”

    “Well,” he said, suddenly a little sheepish. “I also sell lemonade on weekends. And jellybeans shaped like sea creatures. The magic part is more of a theme.”

    Granny Compliance wrote that down.

    “So, you’re not a wizard.”

    “Only at birthday parties,” he admitted.

    Step 3:

    Granny Compliance called a few numbers, checked the records and even looked up his website. Sure enough, Mr Mysterious wasn’t hiding anything serious. His bean-selling was more sugar than sorcery, and his lemonade business was popular in the nearby towns. ‘No criminal record”, “No bad history”, she confirmed.

    She gave him a smile. “Welcome to Bankville.”

    From that day forward, Mr Mysterious became a regular fixture on the street. He sold lemonade with glittery straws and hosted puppet shows for the neighbourhood kids. He never tried to sell anyone magic beans again. Though he once brought cupcakes that changed colour. And everyone knew: thanks to KYC, they weren’t waving at a stranger anymore. They had got to know him properly.

    The moral of the story is,

    Know Your Customer is how banks and businesses (and sometimes cautious grandmothers) make sure people are who they say they are. It’s about asking:

    • Who are you really?
    • What do you do?
    • And can we trust that?

    Because it’s fun to make new friends, but when money’s on the table, it’s wiser to know who’s sitting across from you first.

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    Annual AML Review Checklist for Real Estate Businesses

    Annual AML Review Checklist for Real Estate Businesses

    Annual AML Review Checklist for Real Estate Businesses

    Annual AML Review Checklist for Real Estate Businesses

    Real Estate brokers and professionals in UAE need to focus their attention and resources on closing high-value property deals such as securing commercial lease, dealing with luxury villas, facilitating off-plan purchases, etc.

    However, the real estate sector is prone to being misused by money launderers and criminals to further their illegal motives. That adequately emphasises and calls for conducting an Annual Review of a real estate business’s AML/CFT Program not only to ensure fulfilment of compliance obligations but to diagnose issues in the existing framework by conducting health-check of business’s ML, FT and PF risk mitigation measures. 

    Here’s a checklist for all real estate DNFBPs, including brokers, agents, and other professionals dealing or facilitating with real estate transactions such as lawyers, notaries, and accountants. This Annual AML Review Checklist for Real Estate Businesses  is a comprehensive guide that provides clear roadmap to assess the efficacy of mitigation measures such as: 

    Download this Annual AML Review Checklist for Real Estate Businesses to align your real-estate business’s AML compliance with UAE’s legal requirements and protect your business from financial crimes. 

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    Checklist to Identify the Insider Threats for a Robust AML Compliance Framework

    Checklist to Identify the Insider Threats for a Robust AML Compliance Framework

    Checklist to Identify the Insider Threats for a Robust AML Compliance Framework

    Checklist to Identify the Insider Threats for a Robust AML Compliance Framework

    Regulated Entities must stay cautious of insiders, i.e., employees or executives who can manipulate AML systems, override alerts, or suppress reporting to enable Money laundering (ML) and terrorism Financing(TF) to aid their criminal aids.

    Here is the downloadable and no-questions asked Insider Threat in AML Compliance detection Checklist for AML/CFT + RACI matrix

    This Checklist is specifically designed to simplify AML Compliance teams’ responsibilities, to detect insider complicity or insider involvement through measures such as:

    • Accessing the effectiveness of control measures surrounding employees’ access, authorisations, reporting channels, and whistleblower protections to identify or detect any red flags indicating insider abuse or collusion.
    • Identifying whether regulatory reporting and AML training components are strong enough to mitigate insider risks such as SAR suppression, alert overrider, or tipping-off.
    • Identifying process efficiency for red flag detection related to unusual staff behaviours such as bypassing procedures, privilege escalation, and conflicts of interest. Which may indicate insider involvement in ML, TF, or PF activities.
    • Structuring the operational roles, task allocation, and task escalation for managing insider-threat cases, ensuring segregation of duties and independent internal SAR reviews.
    • Ensuring timely filing of SAR/STRs with the UAE FIU through goAML portal when red flags are detected and reported, without obstruction or delay.

    Download this checklist for Insider Threat in AML/CFT, whether you are in Dubai or Abu Dhabi, as UAE regulations require Financial Institutions & DNFBPs to strengthen governance, protect systems from misuse by insiders and align the business’s AML/CFT measures with realistic insider threat scenarios and red flag indicators.

    This checklist will help you assess your preparedness, mitigate insider risks, and reinforce your AML Framework.

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    Confused with how to mitigate ML, FT, and PF risks within your Regulated Entity?

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