Risk indicators for DPMS – Strategic Analysis by UAE FIU

Risk indicators for DPMS - Strategic Analysis by UAE FIU

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Published On: 11/02/2022

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Last Reviewed On: 08/03/2026   |   Last Updated On: 08/03/2026

Given the fact that precious metals and stones are being highly exploited by criminals to launder money given their size and high liquidity, and the fact that UAE is one of the biggest marketplaces for precious metals and stones trading, the UAE Financial Intelligence Unit (UAE FIU) has recently conducted a strategic analysis of data about Dealers in Precious Metals and Stones (DPMS).

The Strategic Analysis Report lays down the UAE FIU’s objective for conducting this analysis of the DPMS sector as under: 

  • To enhance the understanding of ML/FT vulnerabilities associated with precious metals and stones, 
  • Developing ML/FT trends, typologies, and red flags indicating exploitation of precious metals and stones and the DPMS sector. 

The methodology adopted by the UAE FIU for the strategic analysis of the DPMS sector

The UAE FIU’s strategic analysis is conducted based on the information gathered from the reporting entities operating as DPMS and other relevant stakeholders for January 2021 to June 2022. 

The UAE FIU reviewed the below-mentioned data to analyze the ML/FT trends prevalent in the DPMS sector: 

  1. Dealers in Precious Metals and Stones Report (DPMSR) filed on the goAML portal  indicating cash and wire transfer transactions above the prescribed threshold, 
  2. Suspicious Transaction/Activity Report (STR/SAR), filed either by the DPMS entities or with a “Reason for Reporting” indicating the abuse of precious metals and stones,  
  3. Information exchanged between UAE FIU and counterparty FIUs around gold smuggling, illegal mining of precious metals, gold theft, etc.), 
  4. Information received from domestic authorities – Public Prosecutions, Police Departments, and the Ministry of Interior (MOI) related to an investigation of money laundering and terrorism financing offenses, 
  5. Ministry of Economy’s (MOE) information about DPMS registered in the UAE and MOE imposed sanctions, fines, and warnings to DPMS entities, 
  6. Information received from the Federal Customs Authority around ‘Cash declarations’ wherein the purpose mentioned is related to precious metals and stones. 
Risk indicators for DPMS - Strategic Analysis by UAE FIU

Conclusions of the UAE FIU’s strategic analysis of the DPMS sector

The Strategic Analysis Report addresses the ML/FT typologies and red flags associated with the DPMS sector in the UAE. As per the UAE FIU’s analysis, the following are the major ML/FT typologies or patterns abused to launder money through the DPMS sector: 

Trade-based money laundering

  • Using DPMS entities as “front” to launder the illegal money using trade-based money laundering methods like incorrect invoicing, phantom shipment, or fictitious supply transactions. 
  • Use of multiple DPMS entities as a ‘Corporate Vehicle’ to disguise the source of funds by creating multiple layers by way of transferring a large sum of money amongst the entities without any business rationale. 

The trade-based money laundering is widely used in the DPMS sector to launder money, wherein the transaction is manipulated to transfer the funds from one person to another and from one country to another. 

Other widely exploited trade-based money laundering techniques are: 

  1. To move a large sum of illicit funds from one country (importer) to another (exporter) by over-pricing the commodity supplied compared to its market value. 
  2. Raising multiple invoices on the importer for the same set of products and receiving the payment using different methods to avoid the attention of the authorities. 
  3. Representing the duplicate or fake stones as original and precious stones to bag transfer of large amount from buyer to seller. 
  4. Trade-based money laundering often involves tax evasion, either by short declaring the import quantities or under-pricing the imported goods to avoid paying a large sum of taxes on the import of precious metals. 

Money laundering through “foreign currency exchange” 

  • Indulging employees or third parties into the conversion of foreign currency exchanges without getting the name of the DPMS entity involved anywhere. Here, multiple individuals are involved to avoid reporting threshold and justify the source of funds and purpose as under: 
  • Source of funds used for currency conversion: salary income or savings 
  • Purpose of currency conversion: travel or family upkeep 
  • DPMS is undertaking many foreign currency transactions, mainly in cash, without any logical business transaction or for a quoted reason like foreign suppliers only accepting cash, etc. 

Generally, it has been seen that one currency can be converted into another currency without any involvement of a regulatory authority. Moreover, the conversion of cash currency legitimizes the source of such converted currency, as generally, the party offers receipt of such conversion.  

Moreover, with the increased volume of global trades, the cross-border movement of funds has also risen, leading to increased cases of terrorism financing and laundering funds to invest in unregulated financial centers. 

Gold/cash smuggling 

  • Smuggling gold or illegally transferring the gold from the conflict-affected or high-risk jurisdiction. This smuggled gold or illegally transported gold is sold in smaller quantities to local DPMS entities against cash or is processed and re-exported illegally to different countries, 
  • Sourcing of gold from miners without adequate due diligence of the miner, 
  • Individuals smuggle cash (importing and exporting) on behalf of DPMS entities. 

Using the network of people, gold and other precious metals are increasingly smuggled from illegal miners, wherein quantities of gold are distributed amongst many individuals to avoid the attention of and reporting threshold before the Customs Authority. 

ML/FT risk indicators for DPMS sector suggested in the Strategic Analysis Report 

The risk indicators or the ML/FT red flags captured in this report can be used by the DPMS and financial institutions to identify and report any suspicious activities involving precious metals and stones, Under Article 18 of Federal Decree-Law No. 10 of 2025, read with Articles 17 to 19 of Cabinet Resolution No. 134 of 2025. The following is an illustrative list of ML/FT risk indicators captured in the report involving the abuse of precious metals and stones:  

  • DPMS entities with complex legal structures, created either to hide the UBO or disguise the transfer of funds, 
  • DPMS entity formed as a front company to mix the legally obtained funds with the illicit funds, 
  • Unreasonable behavior of or large complex transactions by newly formed DPMS entities, 
  • DPMS entities extensively transact in cash, 
  • Irregular shipping methods inconsistent with the standard business practice of DPMS, 
  • Inconsistent documentation or forged documents to disguise the transaction, 
  • DPMS frequently enters into transactions of an abnormally large amount, 
  • DPMS having multiple bank accounts without any business sense or DPMS entities operating bank accounts in the employee’s name, 
  • Adverse news about the DPMS’ UBO or senior management, 
  • DPMS or its UBO or management having close association with high-risk countries, 
  • Receipt or payment of money to third parties having no connection with the sanctions, 
  • Transaction structuring into smaller value deposits to avoid reporting threshold, 
  • DPMS entities extensively involved in cross-border cash movement, 
  • Frequent deposit of cash amounts into banks or exchange of foreign currencies by DPMS, 
  • DPMS entities importing precious metals from conflict-affected jurisdictions, or the volume of import is inconsistent with the country of import (having limited mining capacity or no mines), 
  • Failure to furnish ‘Customs Declaration’ concerning cash deposit related to precious metals/stones transaction, 
  • DPMS transacting in gold instead of cash/bank transfer, 
  • Transfer of funds amongst unrelated companies, having no business nexus, 
  • DPMS or its employees engaging in frequent foreign currency conversions without any business logic, 
  • Frequent travel to high-risk areas or illegal mining jurisdictions, 
  • DPMS operates on loans and credit facilities, generally settled before due dates through cash. 

The primary reason for exploiting the DPMS sector 

Given the peculiar nature of precious metals and stones, the same is most vulnerable in the hands of money laundering, using various methods. We have tried to map the main reason for exploitation against the money laundering technique as under: 

Characteristic of precious metals and stones 
Money laundering method 
Global currency – Precious metals and stones are widely accepted as a medium of exchange across the globe
  • Gold smuggling, wherein gold from illegal mines is smuggled or illegally transferred to other countries to supply it in the local market against cash
  • Trade-based money laundering, wherein gold is imported and exported at a manipulated price
High liquidity – Precious metals and stones can easily be converted into cash
  • DPMS entities purchase smuggled gold without any adequate KYC and due diligence process
  • Terrorists convert their illegal funds into gold, which can be easily transported and encashed in the country of operations
Over-the-Counter – Precious metals and stones trading in not regulated over an exchange platform
  • Smuggled gold is sold to the DPMS entities without any adequate KYC and due diligence process
  • Inadequate documentation of the precious metal and stone transaction
Easy transportation – Compact size makes its movement easy
  • Easy movement of gold without much hassle makes it lucrative for terrorism financing and money laundering
  • Terrorists store their illegal funds in gold and transport the same to the country of operations

How AML UAE can help 

AML UAE can help you understand the risk indicators and ML/FT red flags specific to the DPMS sector to identify suspicious transactions and take necessary actions to combat the same (i.e., timely reporting to the FIU).  

AML UAE also helps DPMS entities (including other DNFPBs) set up an in-house AML compliance department and impart AML training to the employees. We are committed to ensuring your compliance with applicable AML regulations and safeguarding DPMS entities against money laundering and terrorism financing threats.  

AML UAE helps you safeguard your DPMS business from ML/FT threats.

Get in touch to know the best preventive and corrective actions.

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About the Author

Jyoti Maheshwari

CAMS, ACA

Jyoti has over 11 years of hands-on experience in regulatory compliance, policymaking, risk management, technology consultancy, and implementation. She holds vast experience with Anti-Money Laundering rules and regulations and helps companies deploy adequate mitigation measures and comply with legal requirements. Jyoti has been instrumental in optimizing business processes, documenting business requirements, preparing FRD, BRD, and SRS, and implementing IT solutions.

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Decentralized Finance (DeFi) and AML implications in UAE

Decentralized Finance (DeFi) and AML implications in UAE

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Published On: 11/17/2022

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Last Reviewed On: 08/05/2026   |   Last Updated On: 08/05/2026

Decentralized Finance (DeFi) and AML implications in UAE

The scope of Decentralised Finance is growing rapidly as the concept of virtual assets is being widely accepted across the globe. Decentralized finance, popularly known as DeFi, is an emerging finance domain that operates very distinctly from the traditional centralized financial system regulated and controlled by a country’s government.

With anonymity and lack of centralized governing authority, the money laundering risk around the same is also very grave. In this context, let us understand what DeFi is and what AML implications are around DeFi.

What is DeFi?

DeFi is a blockchain technology-based borderless and independent financial network. 

Unlike a centralized financial system, there is no central authority governing DeFi, but it is owned by the users who operate and build it. DeFi is an independent system that works autonomously. People trade on the virtual platform, using technology to borrow, lend, invest, or trade without any central authority/intermediary regulating their finances. 

DeFi works on blockchain technology in which the financial services are distributed in a series over the blockchain structure. It is monitored using smart contract programs without the involvement of any intermediary. Protocols are created using open-source software managed by a community of developers of DeFi.  

With DeFi, financial transactions such as lending or borrowing can be done from any place with internet connectivity. A distributed financial database collates and aggregates data from all users and verifies the same using a consensus mechanism (a mechanism used to obtain agreement, trust, and security over a single value or parameter across a decentralized network). 

DeFi is all about peer-to-peer transactions, where two parties come together to exchange cryptocurrency against any supply of goods or services without the involvement of any third parties like banks. Let’s take an example of a loan, where generally you would go to a bank or lending institution and get the money on interest. In the case of DeFi, once you input your loan requirement into the DeFi systems, an algorithm will run to find you a match. Of all the potential peer matches shown, you would agree to the lending terms of one of the peers and get the money on loan. This lending transaction is then recorded in the blockchain. Everything happens at a click of a mouse, and that too in a few seconds. 

Decentralized Finance (DeFi) and AML implications in UAE

What are the benefits of DeFi?

  • It reduces the cost of financial services, which generally the banks and other financial institutions levy for obtaining their services. 
  • Eliminates the intermediaries and establishes direct connections between the parties. 
  • The money is kept in a digital wallet rather than placing it in a bank account.
  • Transferring funds becomes easy and quick. 

What is Virtual Asset Service Provider? 

Here, reference should be made to the definition of VASP as given by FATF, which is as under: 

"A business which conducts one or more of the following activities or operations for or on behalf of another natural or legal person:  

  • an exchange between virtual assets and fiat currencies, 
  • exchange between one or more forms of virtual assets, 
  • transfer of virtual assets; (transfer means to conduct a transaction on behalf of another natural or legal person that moves a virtual asset from one virtual asset address or account to another), 
  • safekeeping and administration of virtual assets or instruments, enabling control over virtual assets, 
  • participating in and provision of financial services related to an issuer’s offer or sale of a virtual asset. 

Can DeFi be construed as VASP or the person controlling it? 

As apparent from the definition above and in the context of DeFi, the DeFi arrangement may fit in the definition of VASP as this technology-based network enables the users to enter if smart contract related to financial services using virtual assets. Thus, DeFi provides a platform to transfer virtual assets between parties by way of a transaction executed between the involved parties. 

As mentioned above, though DeFi qualifies for VASP per se, it cannot be subjected to AML regulations as it is a technology solution or an application. It is essential to understand that even though the name suggests that such software operates on a decentralized ledger, these applications have an authoritative structure where any person or group of a few individuals influence or control DeFi. This control or influence may be related to enhancing the functionalities of the application, aspects related to user interfaces, say, over the governing protocols, or even earning profits out of this network.  

In line with the FATF’s intent to apply the AML regulations to a natural or legal person, the person who is exercising control or has sufficient influence over the DeFi shall be construed as VASP for the purpose of implementing the AML provisions. Accordingly, the owners, developers, or the application operators have to ensure that they undertake due ML/FT risk assessment prior to operating the application as DeFi. This shall also include the implementation of adequate routine AML/CFT procedures and ongoing monitoring measures.

For details on AML/CFT obligation on owners, developers, and operators controlling the DeFi, please refer to our article on Virtual Assets and VASP. 

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Jyoti Maheshwari

CAMS, ACA

Jyoti has over 11 years of hands-on experience in regulatory compliance, policymaking, risk management, technology consultancy, and implementation. She holds vast experience with Anti-Money Laundering rules and regulations and helps companies deploy adequate mitigation measures and comply with legal requirements. Jyoti has been instrumental in optimizing business processes, documenting business requirements, preparing FRD, BRD, and SRS, and implementing IT solutions.

Reach Out to Jyoti

Risk-Based Approach For Dealers in Precious Metals and Stones (DPMS)

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Risk-Based Approach For Dealers in Precious Metals and Stones (DPMS)

Published On: 11/15/2022

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Last Reviewed On: 08/05/2026   |   Last Updated On: 08/05/2026

Risk-Based approach for Dealers in Precious Metals and Stones (DPMS)

The importance of the Risk-based approach for Dealers in Precious Metals and Stones (DPMS) is understood from the nature of the business itself. Jewellers deal in precious metals, stones, jewellery, and by their nature, these items carry high value, and can be easily transported.

Unless a risk-based approach is applied in the jewelry business, it becomes too difficult for the DPMS to comply with the legal requirements of anti-money laundering law in the UAE.

How should DPMS assess the risks involved?

As a part of the risk-assessment process, you must identify specific areas of your business that are more likely to be used by criminals in order to conduct any terrorist financing or money laundering activities.

Therefore, you must assess the risks associated with all your business activities and services. Here are the four primary areas that you need to address while performing while determining your risk.

In order to do so, you must consider the nature and behavior of your clients, the products or services you deliver, and the ways or mediums in which you provide your offerings. However, if you identify any of the situations that suspect unusual or illicit activities, you should instantly control these risks by implementing all the probable mitigation measures.

Read more about AML Compliance Requirements for jewellery business in UAE

What is a risk-based approach cycle?

Here are the crucial steps of the risk-based approach for the Dealers in Precious Metals and Stones:

  • Identifying the inherent risks of your company
  • Creating risk-reduction or mitigation measures and critical controls
  • Efficient implementation of your risk-based approach
  • Reviewing your applied risk-based approach

In order to effectively assess your inherent risks, you can divide the process of risk assessment into two parts.

  • Business-Based Risk Assessment
  • Relationship-Based Risk Assessment

It is crucial for you to note that there is no documented methodology for assessing the risks of your business. Therefore, let us understand both of these processes in detail.

risk-based approach for dealers in precious metals and stones

Business-based risk approach

In order to assess the risk associated with your business, you have to analyze your products, services, delivery channels, and the geographical location of the company. So let us learn about the same in brief.

1- Product and delivery channel

As a dealer in precious stones, metals, jewellery, and stones, you have to assess your products as well as delivery channels in order to ascertain any high risk associated with the same. This may include the following.

  • Buying precious metals, stones, and precious jewels
  • Sale of precious metals, stones, and precious jewels
  • Indirect transactions with unknown clients. These could take place through the internet, mail, or a telephone.
Product-And-Delivery-Channel
Here are a few things that you might want to consider while assessing your product and delivery channels.
  • Assess your products as per the type of market you are operating into, along with the kind of clients they are curated for.
  • Assessing the physical characteristics of your jewellery items is also a critical aspect that you must watch out for. Portability, value, storage options, etc., are considered as the physical characteristics of the products.
  • The jewellery products which are lesser in value usually aren’t subject to significant risks.
  • Determining the modes of communication with your client also has a role to play: face-to-face communication or any form of virtual communication that occurs through the mail, telephone, or video conferencing.
  • Considering the mode of delivering your jewellery items is also crucial and should be thoroughly monitored. Needless to say, the mode of the transaction should also be observed.

Here are a few examples of potentially high-risk products if you are a DPMS.

Gold

Gold is undoubtedly a high-risk product because it is transformable, exchangeable, and potentially provides secrecy in the transactions. In addition to that, gold has a universal price standard, and it can be used as a currency.

Here are a few red flags associated with the trading of gold.

  • An existing customer buying substantial quantities of gold bullion without any legitimate or explainable reason, or a potentially new customer asking for converting vast amounts of gold into bullion.
  • An existing or potential buyer purchases a massive quality of gold and makes the payment in cash.
  • Any known or unknown foreign national buying vast quantities of gold bullion in a relatively short span.
  • The purity, weight, value, and origin of gold are misclassified misleading on the custom declaration forms.
  • Unlicensed individuals or companies producing and commercializing gold.
  • Gold bullion does not meet the industry quality standards.
  • Higher gold prices as compared to the local markets.

Diamonds

Diamonds also possess high trading risks because they are easily concealed, transportable, carry enormous financial value, facilitates secrecy and ease of transacting, and are highly challenging to trace.

Here are a few red flags associated with the trading of Diamonds.

  • A customer is buying diamonds in bulk without having logically explainable or reasonable reasons. The trading of diamonds could be illogical both economically and from a business point of view.
  • Trading of diamonds whose origin is quite suspicious. This is particularly the case with raw diamonds, which are not accompanied by legitimate Kimberley process certificates.
  • A Kimberley process certificate that comes with an exceptionally long validity or is forged.
  • A supplier or customer who is known for trafficking conflict diamonds.
  • A customer or a supplier who is unaware of the best trade practices or the one who seeks help from third parties before finalizing a transaction.
  • Bulk trading of diamonds and the payment is made in cash from the geographical locations where such transactions are unusual.
  • Any customer who requests to purchase polished diamonds in bulk without any logical reasons.

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Behavior of counter parties in some transaction

Here are a few behavioral traits that you must watch out for.

  • Any counterparty that proposes any unusual transaction which is entirely insensible and baseless or the transactions that are pretty high veiled or include high potential profits.
  • Any counterparty who leverages the power of non-banking financial institutions and money service business for no logical and legitimate business reason.
  • Any counterparty that frequently changes bank accounts, especially when on foreign land.
  • Any counterparty seeks secrecy by conducting ordinary business transactions with the help of lawyers, accountants, or any other intermediary.

Various other indicators of High Risk

Here are a few other factors that indicate high risk.

  • A supplier who is not willing to provide accurate or complete contact information, business affiliations, and financial references.
  • Offering loose diamonds in bulk which retains their wholesale value because they can be easily liquidated.
  • Offering risky stones like diamonds through indirect means and to clients whom you haven’t been in direct touch with. These types of transactions are hazardous.

2- Geography

Assess the risk associated with either your own business or the location in which it is located. For example, the movement of money or goods to and from the client company might include high-risk or severe financial crimes like money laundering or terrorist financing.

When you assess your geography, you have to consider whether the geographic locations in which you operate or your clients are based out possess high risks of money laundering activities or terrorist financing. Depending upon the operations of your business, this can range from your immediate surrounding to a province or a territory.

Geography

Here are a few examples of geographic elements that are required in your risk assessment.

  • Locations that experience a considerably higher crime rate may lead to the enhanced potential risk of money laundering or terrorist financing.
  • A rural area where the customers are known to you could present a lesser risk as compared to an urban area where new and anonymous clients are more likely to bring significant risks involved with them.
  • Is your company closely located near a border crossing? If yes, it could elevate the risks involved because your company can be the first entry into the enormous financial systems.
  • If your potential clients are located in countries subject to sanctions or embargoes, you must consider their high risks.

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Various other factors relevant to your company, if applicable

Assessing all the other factors related to your business but that does not fall under any of the previously mentioned headings is also crucial to mitigate or eliminate any potential risks. For instance, the size, structure, employees, and number of branches of your business are a few aspects that also need to be assessed for the availability of any risks.

As a dealer in precious stones, metals, or jewels, you enter a professional relationship when a customer conducts a transaction with you that requires you to determine their identity irrespective of whether the transactions are related to each other or not. If you have a professional relationship with your clients, you need to conduct a risk assessment based on the inherent characteristics of your customers. It can be done on the basis of the following factors.

  • The product you are offering and the channel of delivering you are opting for.
  • The geographical location of either your existing or potential client.
  • The characteristics of your clients.
  • The financial activities and transactional patterns of your clients.

In addition to that, it is quite a possibility that your business deals with clients out of a professional relationship. These types of interactions might be sporadic. As a result, there would not be sufficient information available for your business and the legitimacy of the clients. The risk assessment of these clients is more likely to focus on monitoring transactions than having a file under the name of your client. Monitoring such clients is nothing but an obligation to report any suspicious activities like money laundering or terrorist financing.

Here are a few examples of the characteristics of your clients that you might consider as high-risk.

  • A client who is not at all disturbed or concerned about the price.
  • A client who makes the payment for expensive jewelry in cash.
  • A client who tries to use a third-party credit card or a cheque.
  • A client buying precious metals or stones without having any legitimate interest in the value, size, or color.
  • A client who has unexplainable distance from the offerer or you in this case. A client who orders precious items in bulk makes payment in cash, cancels the order, and gets the refund, preferably through cheque.
  • A client who is not willing to share adequate and accurate amounts of information.

Here are a few examples of transactions that you might consider that you might feel as high-risk.

  • Transactions that look structured in order to avoid reporting requirements.
  • Any transactions that involve third parties, either as payers, or recipients of payment, without apparent logical purpose.
  • Use non-bank financial mechanisms, like currency exchange or money remitters, instead of a legitimate banking system.
  • Any kind of unusual payment methods, like large amounts of cash, multiple numbers of money orders, cashier’s cheque, traveler’s cheque, or any type of payment from third parties.
  • Funds that come from an offshore financial center instead of a local bank.
  • There are multiple affiliated entities in the payments chain.

Final words

Dealers in precious metals and stones are already more prone to dramatic risks. But it is essential to apply a risk-based approach in the same. The entire process is quite challenging and needs expert advice and help, and this is when AML UAE comes into the picture to provide its expert AML Consultancy Services.

Frequently Asked Questions (FAQs)

Here are a few frequently asked questions.

Which all types of risks should be assessed in order to carry out risk profiling for DPMS?

Here are a few risks that you need to assess in order to carry out an adequate risk profiling for dealers in precious metals, stones, and jewels.

  • Product, service, and transaction-related risk
  • Supply channel-related risks
  • Geographical risk
  • Client-based risk

The entire industry is prone to high risks. In order to keep yourself safe from reputational losses and regulatory penalties, you have to follow a few things deliberately.

  • Ask your clients to fill up a KYC form and submit legally authorized documents to verify the details provided.
  • You must also check the name of the purchaser in sanction lists, PEPs list, or adverse media reports details.
  • Verify the details, and if any suspicious activity is diagnosed, you must immediately follow an enhanced due diligence process.
  • If you suspect any type of money laundering or terrorist financing, you
    must immediately file a STR.

The entire process can be pretty time-consuming, and your clients might feel frustrated. However, there are a few things you can do in order to engage with them while all other essential aspects are being carried out.

  • Offer some refreshments
  • Engage the client by showing a video of your warehouse where the jewelry masterpieces are being designed and curated.
  • Ask the client whether they would like some loyalty cards for future purchases.

Annex A: Business-based Risk Assessment
Here are the instructions in order to complete the business based risk-assessment which includes products, geography, delivery channels, and many other relevant factors.

AList of FactorsEffectively describe your products, factors related to geographic locations, and delivery channelsBRisk RatingThere are multiple risk factors, and all you have to do is to rate all of your risk factors. Risk factors include delivery channels, nature of products & services, geographic locations, and many other relevant factors. It is important to note that you can have either a low or high-risk category or to have a legitimate complex rating scale. Moreover, the scale you develop should be established, tailored as per the size and nature of your business.CRationaleWhenever you assign a risk rating to all the risk factors, it is important to provide a reason for that. Furthermore, if required, you can even make a reference to a website, a report, or a published paper. Describe Mitigation Measures For High-Risk FactorsAll the factors identified as high-risks should be addressed with documented mitigation measures. Written policies and procedures will make it easy for you to explain how you will reduce or control these risks in your daily activities.

Here are a few examples of mitigation measures you might want to consider.

  • Enhance your awareness of high-risk situations in your company line across your enterprise.
  • Facilitate targeted training to staff regarding probable red flags and indicators of high-value, high-risk products such as diamonds or gold.
  • Facilitate adequate controls for relatively higher-risk products like management approvals.
  • Enhance the overall frequency of monitoring transactions that are associated with relatively high risks.

Annex B: Client relationship-based risk assessment
Here are the instructions in order to complete the client relationship-based risk assessment:

AHigh-Risk Clients or Business RelationshipsDetermine all your high-risk business relationships and clients. You might want to assess risk each business relationship individually or maybe in groups that share almost the same characteristics.BRisk RatingYou must rate each of your business relationships. You might use a scale of the low, medium, or high in order to risk rate your business relationships.CRationaleMention a reason why you assigned a particular risk rating to each of your clients or business relationship. Describe Enhance Measures In Order To Determine The Identity of or Existence of High-Risk ClientsDescribe how the identity was determined or how the existence of a high-risk entity for each high-risk client or business relationship was identified.

Here are a few examples.

  • Seeking some additional information beyond even the minimum requirements in order to ascertain the identity of the client.
  • Get the independent verification of the gathered information.
  • Establishing more strict and rigid thresholds for ascertaining identification.

EDescribe Mitigation Measures For High-Risk FactorsYou have to mitigate and control the risks of each high-risk client or business relationship you have identified.

Here are a few examples of mitigation measures you might want to consider.

  • Set limits to transaction amount in specific situations.
  • Ask about the source of funds in case of any cash payment.
  • Conduct a few transactions only in person.

FDescribe How Will You Keep Client Information Updated For High- Risks Business Relationship And ClientsYou are required to build policies on how and often you will update the information of the high-risk clients or business relationships. The information that usually needs to be constantly updated includes the following.

  • If the client is an individual, name, address, contact number, and the occupation of that individual.
  • If the client is a corporation, name, address, and the name & address of the directors of the corporation.
  • If the client is an entity or something more than a corporation, name, address, and the principal place of the business.

Methods to keep client identification updated include asking the client to provide information to confirm or update information related to your identification.

GDescribe Enhanced Monitoring For High-Risk Clients And Business RelationshipsFor high-risk clients and business relationships, you require to conduct enhanced monitoring.

Here are the things that you need to keep in mind when it comes to the enhanced monitoring process.

  • What should be the frequency of the enhanced monitoring?
  • How is it conducted?
  • How will it be reviewed?

Here are a few examples of how enhanced monitoring is conducted and reviewed for high-risk clients and business relationships.

  • Ask for additional information like volume of assets, occupation, and information available through public databases.
  • Review transactions on the basis of an approved schedule that includes management sign-offs.
  • Set business parameters or limits related to transactions that would figure out early warning signs.
  • Try to review transactions more frequently against any type of suspicious activities related to high-risk clients or business relationships.
From an AML perspective, precious metals are considered high-risk and associated with ML/FT typologies. Precious metals, owing to their size and value, offer a lucrative market to the money launderers – as they are easy to hide, transport, and hold as investments of their huge illegal funds in small volumes.
Ghost shipping under AML indicates a bogus or fictitious transaction, wherein buyer and seller come together to prepare fake documents for the fictitious transaction indicating that the goods were supplied and payments were made, where neither there has been any goods movement nor any payments transferred. Ghost shipping is one of the Trade-based money laundering methods.
Precious metals can be traded over the counter with dealers in precious metals (not being regulated on exchanges), wherein the prices of the precious metals are speculated and impacted by demand and supply.

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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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What is terrorist financing?

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What is terrorist financing?

Published On: 11/15/2022

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Last Reviewed On: 08/05/2026   |   Last Updated On: 08/05/2026

What is Terrorist Financing?

Terrorist financing is one of the most complex and troublesome financial crimes across the world. The financing of terrorism is an offence under Article 3 of Federal Decree-Law No. 10 of 2025; the related targeted financial sanctions regime is outlined under the Cabinet Resolution No. 74 of 2020 and the EOCN TFS Guidance (March 2026).  The potential and level of impact of terrorist funding have increased dramatically in the last few decades. Terrorists require a considerable amount of money in order to execute their ill intentions. As per the current state of terrorism across the world, terrorist financing makes available for non-state actors or individual terrorist accommodation, training & development, funds to buy or test weapons and to cater to other financial needs for observing terrorism in the world.

How are funds for terrorism provided?

The funds for terrorism are provided through several means; a few of them are listed hereunder:

  • Huge sum of money is obtained through several illicit activities
  • Leveraging the power of money laundering activities in order to utilize the illegally occupied cash in a more destructive way
  • Obtaining massive sum of money with the help of criminal activities like smuggling of drugs, kidnapping, fraud, money laundering, and extortion
Terrorism Provided

Anti-money laundering or AML regulations are a key measure to counter-terrorist financing. Financial institutions (FIs) and Designated Non-Financial Businesses and Professions (DNFBPs) play a vital role in combatting the financing of terrorism simply because criminals or terrorists mostly rely on them, especially banks, in order to transfer illicitly occupied funds.

Therefore, many regulations and laws have been enacted in order to prevent terrorist financing, primarily known as counter-terrorist policies. As per the counter-terrorist policies, financial institutions should know their customers closely.

Therefore, they should monitor and keep records of the transactions of the customers or clients. In this manner, business enterprises can have sufficient information related to their customers and ensure that their customers or clients are not involved with any financial crimes or illicit financial activities.

Suppose a massive sum of money is found with an intention to support terrorist activities. In that case, law enforcement agencies will come into the picture to combat some of these crimes or illicit financial activities.

Financial Action Task Force (FATF)

FATF is an abbreviated form of Financial Action Task Force established in 1989 by G-7 countries to prevent money laundering activities from the economy as a whole. The FATF comprises 35 governments and two regional organizations. The FATF is working in order to combat terrorism financing and money laundering by developing standardized procedures to stop the threats to the international financial system.

Criminals like terrorists can infiltrate the economic system of several countries with weak controls. Therefore, it is pretty challenging to check the financing of terrorism by establishing standard procedures. The FATF standards require governments to take several legal measures to ensure that the serious crime of terrorism financing, covering most of the elements stipulated by the convention of terrorism financing, be punished as a separate crime altogether.

Furthermore, the FATF reflects the measures created to counteract money laundering activities and make sure that the implementation of the private sector’s required preventive measures is being taken in the best possible manner.

The Terrorism Prevention Branch or the TPB of the United Nations (UN) office on Drugs and Crime (UNODC) sweats on the legal aspects of all the relevant universal legal documents that are proudly countering terrorist financing.

This law usually includes a review of internal legislation to counter terrorist financing and the appropriate punishment of crimes. It also provides for the implementation of all of these international standards and empowers law enforcement officials with specialized training.

Anti-money laundering compliance solutions

Terrorist financing is a serious criminal activity that can have severe consequences. These illegal activities are perceived as financial crimes like money laundering, which involve obtaining vast amounts of money through several illicit methods. Therefore, all financial institutions and DNFBPs at the risk of terrorist financing should comply with the home country and global regulations such as FATF. Although compliance with these regulations appears complicated, complying with them has become much easier with the help of anti-money laundering-related technology-based solutions.

Anti-Money Laundering Compliance Solutions

How can AML or CFT tool help?

Here are a few ways in which AML/CFT tool can help:

  • AML and CFT can lead to forfeiture and recovery of unlawfully acquired assets
  • It aids the authorities with legitimate roadmaps to identify those who facilitate illicit and criminal activities
  • Expose the infrastructure of criminal or illegal organizations conspiracies and webs of corruption to commit inhuman terrorist attacks
  • Support effective and broad deterrence efforts against a wide range of illicit and unlawful activities, including the funding of terrorism

In addition to that, clear and effective communication is a must for an anti-money laundering Compliance Officer because he is the one who is in touch with almost all the employees of the business enterprise and also has the responsibility to report the suspicious transactions to the Financial Intelligence Unit on behalf of the organization. Therefore, a Compliance Officer is expected to share an essential piece of information with the Company’s staff at a specific time to ensure adherence to AML/CFT regulations.

About AML UAE

The above information clarifies the meaning of terrorism financing and the negative impact it can have on the economy of the organization and the country as a whole. However, in order to combat this terrorism funding, any business entity has to follow a few steps and control their relevant internal legislation minutely. For that, one may need expert help like us, AML UAE.

AML UAE provides various services like drafting of AML Policies and implementation thereof, setting up on internal AML Compliance department, AML training, and assistance in the selection of AML Software. Get in Touch Now!

Frequently Asked Questions (FAQs)

What steps should be taken to close off the options for terrorist financing?

  • Strict enforcement of AML/CFT Laws
  • Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) measures
  • Fines and Penalties on violators
  • Filing of STR (Suspicious Transactions Report) with the FIU

Here are a few actions that must be taken to enhance the overall financial intelligence in the battle against terrorist financing:

  • By introducing whole new centralized banking and payment account registers
  • By aligning the rules of Financial Intelligence Units with the latest international trends
A. Intention or purpose of crime:
  • Money laundering: To hide the source of illegal funds and integrates such funds into the legit financial system
  • Terrorism financing: Collating funds to carry out terrorist activities to threaten the peace and integrity of the society
B. Source of funds involved:
  • Money laundering: As the definition suggests, the source of funds involved in laundering is always illegal
  • Terrorism financing: Funds collected for terrorist activities may not always be illegally obtained, as sometimes genuine profits are also diverted for terrorist activities
C. Driving force for conducting crime:
  • Money laundering: Generating more profits through illegal activities
  • Terrorism financing: Driven by ideologies and emotions to adversely affect the society
D. Stages & Process
  • Money laundering: This is a cyclical process, where profits generated through illegal activities are-invested back into illegal activities. Involving 3 stages – Placement, Layering, and Integration
  • Terrorism financing: This is a straight/linear process where funds are consumed for carrying out the terrorist activities
E. Stages
  • Money laundering: 3 stages – Placement, Layering, and Integration
  • Terrorism financing: 4 stages – Collecting, Storing, Moving, and Using
The following elements make the tracing of terrorism financing challenging:
 
  • Terrorism financing hardly follows any pre-determined pattern, and that too is not fixed all the time,
  • Terrorist groups are aware of countermeasures being deployed. They identify the loopholes to avoid the attention of authorities and evade these measures,
  • Terrorism financing involves other criminal activities like smuggling, narcotics, money laundering, etc., which complicates the terrorism funding process,
  • Involvement of multiple countries and high-profile individuals,
  • Counterfeiting and increased use of cash instead of digital/bank transfers do not leave any trail to identify the source of such funding

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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.

Reach Out to Pathik

Why gold is still the second-best mode for money launderers

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Why gold is still the second-best mode for money launderers

Published On: 11/15/2022

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Last Reviewed On: 08/05/2026   |   Last Updated On: 08/05/2026

Why money launderers prefer using gold for money laundering

Other than using Gold for Money Laundering, the uses of gold are wide-ranging and well-documented. Since ancient times, gold has been used in various cultures as a medium for exchange or payment. Historically, governments minted coins out of a physical commodity such as Gold, Silver, Copper, and Bronze. In addition to its value as an investment, the physical appearance and properties of gold lend themselves to be used in jewelry and for various technological/manufacturing uses.

For example, in many developing countries, gold jewelry is not only perceived as an adornment but also as an effective savings vehicle. Even now, the Gold reserve of the country determines its creditworthiness. Gold stands tall as a status symbol and has a lot of cultural values too. Hence making Gold for Money Laundering as a perfect choice. It is also an instrument of investment.

As the financial regulators grow strong and robust, so do the Gold for Money Laundering methods. The inventions and discoveries on Gold for Money Laundering methods and trends never end. Precious metals like Gold, Platinum, and silver were not much on anyone’s radar. So when banks tightened the noose, the money launderers resorted to precious metals like gold and platinum, and real estate, etc., to use Gold for Money Laundering.

Using Gold for Money laundering is not a new trend. This comes from history. The BFSI industry is shutting its door one by one, so money launderers will find some new trends or retrofit the old trends. One does not need a tax identity to buy gold. This paves the way for using Gold for Money Laundering in all 3 layers of Money laundering. Gold seems to be lucrative for all sides of the transaction.

second-best-mode-for-money-launderers

The regulatory authorities identified this trend, and it started monitoring the precious metals sector by bringing it under the preview of the AML law UAE by terming them as Designated Non-Financial Businesses and Professions (DNFBPs).

AML Compliance Requirements

12 reasons why Gold for Money Laundering is used:

money-laundering-purposes

1. Contango:

The gold market is mostly in Contango. This means the Future price of gold is greater than the spot price. Even during the downtimes, gold has been the prime choice for commodity trading.

2. Liquidity:

The liquidity of gold is high when compared to other modes of investments like Bank FDs, Stocks & Mutual Funds. Unlike the other investment products, you don’t need a bank account to buy or sell gold. Redemption from gold is instant & we can get ready-cash instantaneously.

3. Always OTC:

Gold can be sold anywhere Over the Counter & isn’t controlled by any exchange. Unlike markets, you can even sell or buy on weekends too. It is easy to find buyers or sellers for gold rather than stock. Hence they use Gold for Money Laundering.

4. Tax:

There is no tax associated with gold when you go with an investment perspective. The sales tax or VAT is all that you pay.

5. Return on investment:

Unlike Stocks/Bonds, Gold will give reliable returns depending on the market rate.

6. Attractive for tax evaded money:

Money laundering need not necessarily be done for Terrorist financing or illicit proceeds. Sometimes people launder the money that was evaded from tax. This can be rental income, Benami transactions, money coming from Hawala transactions/remittances.

7. Efficient:

Gold can be used in all 3 layers of Money Laundering. Be it Placement or Layering, or Integration.

Stages of money laundering-01

8. Global currency:

Gold is considered a global currency. One can buy or sell gold anywhere around the globe. There is no currency conversion or loss there. One can buy it in the eastern part of the world and sell it in the west without losing the face value.

9. Complex transactions:

The transactions involving the gold or jeweller are too complex to drill down. There might be multiple persons involved on both sides of the transaction.

10. Transformable:

Gold can be changed into many forms (Jewelry) and denominations (Coins / Bars) without losing the face value. This helps money launderers to use gold for Smurfing or Smuggling and many such methods.

11. Win-win game:

The jewellers need gold for trading and manufacturing purposes. So there’s always a demand for it. It’s a win-win situation for dealers in precious metals and stones, and the money launderer as both of them get to trade for their benefit.

12. Lack of regulatory reporting:

Unlike Banks / FIs, they can keep their transactions under their control. In many countries, there is no periodic submission of Cash transaction report or Suspicious Transaction report. Such a multi-faceted commodity somehow missed the attention of the regulators. Even if it comes to a need for supervision, there will be a question of ‘Who will regulate the gold?’ Will it be the commodity market? Or the Central Bank? Or the Government?

FAQs on Gold for Money Laundering

Why are precious metals high-risk?

From an AML perspective, precious metals are considered high-risk and associated with ML/FT typologies. Precious metals, owing to their size and value, offer a lucrative market to the money launderers – as they are easy to hide, transport, and hold as investments of their huge illegal funds in small volumes.

Gold carries high value compared to its volume and is considered one of the best mediums to store funds and transport them easily across borders. Further, gold can be easily traded anywhere and anytime, with the realization of the optimal value.

Gold is easy to store and has its value (almost the same) across the globe. Investment in gold offers a higher rate of return than bank rates, as the value of gold is subject to speculation based on the demand and supply of this metal. Moreover, it is considered one of the best hedging tools against inflation.

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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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Importance of AML/CFT measures

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Importance of AML/CFT measures

Published On: 11/14/2022

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Last Reviewed On: 08/17/2026   |   Last Updated On: 08/17/2026

Importance of AML/CFT measures

As the world economy is growing and the entire globe is coming together as an integrated society, two vices are trying to take a toll on this society – Money Laundering and Terrorism. Money laundering has been a setback to the global financial system, pumping the illegally generated money into the economy, making it appear to have come from a legitimate source. Such funds generated from criminal activities are used again for multiplying the effect of illegal activities, such as terrorism, and impacting the security and integrity of the countries. The need of the hour is to be resilient against such evils of the society to make it a better place to live, and thus, various countries are coming up with the Importance of AML/CFT measures.

AML/CFT Measures undertaken by various countries

Due to sheer Importance of AML/CFT measures, Singapore Ministry of Law has developed a division under the name of “Anti Money Laundering / Countering Financing of Terrorism,” with whom Cash Transaction Report for suspicious transactions is furnished.

Similarly seeing the Importance of AML/CFT measures, the Australian Government has issued the Anti-Money Laundering and Counter-Terrorism Financing Act in the year 2006, which requires businesses to have a proper program in place to protect the company from financial crimes by timely identification/mitigation of these kinds of risks.

Importance of AML/CFT measures

AML/CFT measures undertaken by UAE

The United Arab Emirates is also one such nation amongst the list who understands the Importance of AML/CFT measures, and is devoted to controlling the money laundering activities and financing of terrorism or other illegal activities from there. As a part of this strategy, the UAE government has introduced the regulation “Anti-money laundering and combating the financing of terrorism and the financing of proliferation (Federal Decree-Law No. 10 of 2025)” and issued the guidelines to enforce the law better.

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Designated Non-Financial Businesses and Professions (DNFBPs)

Designated Non-Financial Businesses and Professions (DNFBPs)

If one deep dives into the lawmakers’ intent, one would understand that DNFBPs have been categorized looking at the risk involved in the business or the vulnerability of business towards the criminal activities or the one having access to the suspect’s accounts/ finance details.

If we take the example of auditor, the federal laws regulating the audit profession anyway imposes specific obligations on auditors regarding the reporting of crimes detected during auditing the accounts of clients, as they have access to the books and internal controls.

When it comes to protecting the financial sector from such criminal exploitation, certain businesses and professions could serve as first aid to curb these. With the same thought, under UAE guidelines, class of people/businesses have been defined as <strong>Designated Non-Financial Businesses and Professions</strong> (“DNFBPs”).

They have been obligated under the law to perform the Due Diligence of their customers and risk profiling. These DNFBPs have been made responsible for reporting the transactions to the authorities, where any suspicion involving money laundering or illegal activities such as financing terrorism, drug trafficking, etc., is doubted.

It is pertinent to know the group of businesses and professions that have been identified as DNFBPs. This list includes the following:

Let’s talk about precious metals and stones. The high intrinsic value of the product vis-a-viz the compact form of the same and the value appreciative nature of such items (gold, silver, diamonds, etc.) make it easy for the money launderers to exploit the sector and fund the criminal activities.

Looking at the nature of business/professions obligated with tasks under anti-money laundering and combating of financing of terrorist activity, it is apparent that the purpose is to trace back such money launderers and check the illegal or criminal activities. For this, it is important to have in place a dependable source of information about the business relationships and transactions. This is pertinent as the money launderers and the persons involved in criminal activities try to hide their identity and camouflage the proposed transactions.

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Responsibilities of DNFBPs

In the context of the responsibilities shouldered on the DNFBPs, it would be treated as an offense if they do not report the suspected transactions (where they doubt the involvement of money laundering or any other criminal act) or tip-off about the transactions reported with the supervisory authorities.

For this, the regulations have suggested specific ways and means to assist the DNFBPs to comply with the guidelines and discharge their obligations of reporting the suspicious transaction in a fair method, such as:

About AML UAE image

Thus, the law revolves around adequate measures for identifying customers and risk assessment to evaluate the cause for concern and report the same to apt Governmental authorities for necessary proceedings against the felonious person.

FAQs On Importance of AML/CFT measures

What is the purpose of AML/CFT regulations?

AML/CFT regulations are essential to fight financial crimes – money laundering and terrorism financing – to ensure the integrity of the society and stability of the country’s financial system and the whole world, mitigating the adverse effect of such crimes on society. Having AML/CFT measures as regulations would mandate the country’s ordinary people to join this fight.
AML/CFT requires the designated entities to implement countermeasures to fight against money laundering and terrorism financing, such as implementing the robust AML/CFT compliance framework, verifying a person’s identity before transacting, staying alert to any red flags, timely reporting of suspicious activities, etc.
 
Combatting terrorism financing is critical as it facilitates funds to the terrorist group for their operations, propaganda, etc., which ultimately impacts global peace and threatens society. It also results in the rise of other criminal activities like human trafficking, the use of narcotics, etc. Thus, CFT becomes pertinent to prevent incidences of terrorism.
Having robust AML guidelines in place would leverage a country in fighting financial crime with the united support of fellow citizens. Further, predefined guidelines will clearly lay down the government’s intention, ensuring that the prescribed best practices to fight money laundering are followed consistently across the nation.

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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.

Reach Out to Pathik

Know Your Business (KYB) – Key element of AML compliance

Know Your Business (KYB)

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Published On: 11/10/2022

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Last Reviewed On: 08/18/2026   |   Last Updated On: 08/18/2026

What is Know Your Business (KYB)?

Know Your Business or KYB is the process of identifying the authenticity of a business with which the company deals. Customer due diligence is a statutory obligation under Article 19(1)(b) of Federal Decree-Law No. 10 of 2025, with the detailed measures set out in Articles 6 to 15 of Cabinet Resolution No. 134 of 2025Identifying and verifying the beneficial owner is required under Article 19(3) of Federal Decree-Law No. 10 of 2025 and Articles 9 and 37 to 41 of Cabinet Resolution No. 134 of 2025. It might be suppliers, third-party consultants, intermediaries, or B2B clients or customers. KYC process would be relevant for any business organization directly dealing with the company.  

Know Your Business is an essential step toward protecting an organization from financial crimes. Similar to the Know Your Customer (KYC) process, KYB is a practice followed by the companies to know with whom they are doing business. For every organization, it is very critical to be aware of their business partners. Their identities need to be verified and validated. The foundation of a business relationship with another business should be based on a proper KYB procedure. 

It serves two purposes – it enables a business to know that the business it deals with is real and a lawful entity. It is not a shell company that is commonly used as a technique to launder money. Secondly, it lets the business know whether the persons controlling and running the business are involved in any criminal activities. 

Therefore, KYB is a common practice in the B2B sector. Many companies rely on it to know if they are dealing with legitimate companies and lawful entities with a genuine legal structure. 

Know Your Business (KYB)

Why is KYB needed? 

Increased instances of money laundering have urged companies to adopt a strict approach towards safeguarding their company from being exposed to financial crimes, with procedures and methods to know the customers and business partners. Since the money laundering typologies are evolving and moving towards the use of network structure, the focus now should be on knowing the legal persons with whom the company is transacting by the “Know your Business” process.  

Identifying the legal structure and its ownership is a top concern when dealing with other businesses, which is an essential process. By following the best KYB practices, the companies can identify the structure and people operational for conducting financial crime well in time and thus, reduce the possibility of financial crimes. Adequate and effective KYB procedures would keep the customers’ and stakeholders’ interest in the business intact and save from reputational and monetary damages. 

Are KYC and KYB the same? 

KYC and KYB are both verification processes targeted at different customer categories. 

The subject of the verification differs in both cases – KYC is for verifying the identities of an individual customer or business partner (natural person). At the same time, KYB aims to assess businesses (legal persons) and those controlling, owning, and running these businesses. 

However, both the processes have a common aim: to identify and verify the identity of the person with whom the company is transacting to deter criminals from misusing a business’s financial structure for money laundering and other financial crimes. Both methods help comply with the AML rules and regulations and safeguard an institution from reputational damage caused by being vulnerable to financial crimes. 

Know Your Customer - KYC Requirements under AML regulations in UAE

The increasing importance of KYB 

KYB is a new entrant into the framework of risk mitigation and prevention of financial crimes. KYC has been in place for a long time to help organizations protect themselves from financial crimes but was focused more on the customer segment. Now, realizing the growing importance of dealing with all the business associates and the spread of money laundering networks, one glaring gap has attracted everyone’s attention – verifying a business’ identity. Now with KYB, business relationships are monitored with the same effectiveness as the assessment of individuals as per the KYC process. 

The US Financial Crimes Enforcement Network (FinCEN) introduced the KYB regulations to implement a standard procedure for verification of the legitimacy of a business. KYB is vital because criminals may use different ways and create various sources to launder money, such as shell companies, which exist only on paper and are used to transfer illicit money.  

Moreover, criminals also use legitimate businesses to launder money and fund terrorism and other criminal activities. Considering this aspect, US FinCEN introduced the KYB regulations. When carrying out the Due Diligence process, KYB has also become a standardized procedure that businesses employ to verify the identity of the organization they work with. 

Elements of the Customer Due Diligence Process

Who should conduct KYB? 

KYB is fast gaining acceptance, and businesses realize its importance. Companies should conduct KYB to identify and prevent financial crimes timely. They can comply with the regulations and protect their business from criminals who often target legitimate businesses for money laundering. It should be a common practice for banks, financial institutions, and companies to conduct KYB procedures. 

Wholesalers, manufacturers, and suppliers who deal with other companies must know their counterpart’s identities. 

KYB will let a business know that their associates are legitimate, and they will not have to face legal repercussions while doing business with them. 

Steps to Conduct KYB

Verification of Business

KYB helps determine that the business is not a shell company and exists in reality. It also verifies that the activities and operations the business is conducting are lawful and the business per se is legitimate. It assures a business that the organization is genuine and is not involved in any unlawful activity. 

Different documents should be sought and reviewed to establish the authenticity of a business, such as: 

  • Registration documents and certificate of incorporation 
  • Ownership structure 
  • Constitution of the management or board of directors 
  • Financial statement, if possible 

Verification of business owners 

After knowing that the business activities and operations are legitimate, the next step is to verify the authenticity of the business owners and the controlling parties. The verification will reveal if the owners and stakeholders are law-abiding citizens with no criminal records.  

An essential aspect of the verification of business owners is also termed Ultimate Beneficial Owners (UBO) verification. The process consists of identifying UBOs and evaluating if they are genuine natural persons, not merely names existing on paper. Moreover, businesses should verify whether any of the UBOs are on sanction lists 

With such a thorough verification process, a company can make informed decisions about maintaining or continuing a business relationship with the entity. 

Identify UBOs to complete your AML Customer Due Diligence

Simplifying Know Your Business 

KYB is an essential process that businesses should follow to know the authenticity of their associated companies. It may be suppliers, manufacturers, wholesalers, logistics partners, or intermediaries. The KYB process is laden with several challenges, which businesses can simplify with the help of experts. The significant challenges in the KYB process are: 

  • Collation of different documents and information from various sources  
  • Verifying the information collected from varied sources and screening them against different databases to establish the authenticity 
  • Compilation of the KYB procedure – its proper documentation 

Given the critical factors involved, it is recommended to rely on technology to implement the KYB procedure correctly to avoid the risk of non-compliance. Technology and advanced software would ensure accurate results and streamline the process to yield faster and more comprehensive outcomes. Automated verifications with the help of software are an ideal solution for any business that wants to diligently comply with the KYB regulations. Outsourcing may also help conduct the manual verification process seamlessly, without the need to invest in technology and own workforce. 

Implement Know Your Business (KYB) processes with professional support

AML UAE is a team of expert advisors offering AML Compliance services on a wide range of services such as KYC & KYB, AML Policy, procedures and controls documentation, AML training, etc. 

Designing a comprehensive AML Training Program

We help businesses in the B2B segment to understand the authenticity of the organizations they are doing business with. KYB will help companies to comply with the verification rules and regulations, safeguard the interest of their customers and stakeholders, and protect their reputation from being tarnished by criminals for their illicit gains. 

By outsourcing the AML compliance services and KYB procedures, you can benefit from the expertise of compliance experts who will seamlessly handle KYC and KYB procedures.

Our experts use technology to deliver accurate results. Get a complete check on your customers and companies you are doing business with – be it KYC, KYB, business or customer Due Diligence, Enhanced Due Diligence, identification of PEP or UBO, and sanction screening results.  

PEP and PEP Screening under UAE AML Regulations pre

Get peace of mind with our professional identity verification, authentication, and validation approach. It will allow you to concentrate on business growth rather than getting caught up in the KYC and KYB regulations. Get in touch with our expert team and how they can help you with the KYC and KYB processes. 

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For your smooth journey towards your goals

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About the Author

Jyoti Maheshwari

CAMS, ACA

Jyoti has over 11 years of hands-on experience in regulatory compliance, policymaking, risk management, technology consultancy, and implementation. She holds vast experience with Anti-Money Laundering rules and regulations and helps companies deploy adequate mitigation measures and comply with legal requirements. Jyoti has been instrumental in optimizing business processes, documenting business requirements, preparing FRD, BRD, and SRS, and implementing IT solutions.

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What are AML compliance requirements in DIFC? 

AML compliance requirements in DIFC

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Published On: 10/07/2022

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Last Reviewed On: 08/18/2026   |   Last Updated On: 08/18/2026

What are AML compliance requirements in DIFC?

Dubai is a financial hub and an epicenter for trade activities in the Middle East and Gulf region. Thousands of businesses, along with banks and financial institutions, operate in the world’s most popular financial center in Dubai, the Dubai International Financial Centre (DIFC). 

Even the designated businesses operating in the DIFC are also subject to AML rules and regulations obligated to implement proper measures to fight money laundering and terrorism financing in this region to support the DIFC position. 

DIFC implements various AML rules and regulations and operates as full-fledged jurisdiction to combat money laundering and mitigate its risks. It is supervised by the Dubai Financial Services Authority, which addresses the burning issue of money laundering and other financial crimes rampant in this particular economic zone. Firms should be mindful of the DFSA regulations and comply with them to avoid penalties and contribute to the government’s mission of reducing exposure to financial crimes. 

DIFC and Its Regulatory Authority DFSA

DIFC is a leading international financial hub in the Middle East, Africa, and South Asia (MEASA) region. The Dubai Financial Services Authority (DFSA) is the DIFCs financial regulatory agency. It is authorized to protect DIFC and the economy against money laundering and terrorism financing by implementing the relevant rules and regulations.

What are the AML Regulations applicable to companies operating in DIFC?

The UAE federal legislation was created to follow the international AML/CFT standards and recommendations provided by the Financial Action Task Force (FATF). The crucial acts of the federal legislation that guide AML compliance in Dubai is mentioned as follows: 

  • Federal Law No. (4) of 2002 was implemented to combat Money Laundering and Terrorism Financing Crimes. It criminalizes money laundering and requires all relevant persons to report any suspicious transactions to the Financial Intelligence Unit of the UAE. 
  • Federal Decree by Law No. (10) of 2025 is a crucial law on Anti-Money Laundering and Combating the Financing of Terrorism and the Financing of Proliferation. This law is a vital component of the UAE’s efforts to prevent financial crimes, and it helps to improve the efficiency of the legal and institutional bodies in the UAE (including Cabinet Resolution No. (134) of 2025.
  • Regulatory Law DIFC Law No. (1) of 2004. 
  • DIFC’s Non-Financial Anti-Money Laundering/Anti-Terrorist Financing (AML/CFT) Regulations 
  • The DFSA Rulebook – Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module as applicable to Financial Institutions, Designated Non-Financial Businesses and Professions (DNFBPs) and Virtual Asset Service Providers (VASPs).

DIFC Regulatory Law of 2004 provides that the companies within the DIFC must follow the rules and regulations established by the UAE, i.e., other federal laws. There are certain obligations that the banks and other financial institutions have to follow to obtain a license and operate in the DIFC. 

AML compliance requirements in DIFC

What are AML Compliance obligations for businesses operating in DIFC? 

The Financial Action Task Force has provided recommendations for AML/CFT compliances. Further, per DIFC’s AML/CFT regulations, the firms in the DIFC have to create an effective AML/CFT program by evaluating the money laundering risks they are likely to be vulnerable to. The standard practices they have to follow for AML compliance are mentioned below: 

Customer Due Diligence:

Firms need to adopt a risk-based approach to combat money laundering risks, so they need to put appropriate CDD measures in place to verify the customer’s identity. Customers identified as high-risk should be subjected to the Enhanced Due Diligence process. 

Elements of the Customer Due Diligence Process

Transaction monitoring:

It is vital to monitor the transactions continuously and identify any money laundering risks during the customer relationship journey. Businesses can take the help of AML Software to spot any suspicious transactions and unusual patterns in the transactions and identify any fraudulent financial activity. 

What are AML compliance requirements in DIFC?

Screening:

Screening is crucial in the entire AML compliance framework as it helps businesses identify the individuals or entities who have been sanctioned or involved in any financial crime-related activities. Firms need to screen customers to determine whether any of the person or their UBO is Politically Exposed or not. They also need to monitor their customer databases and match the names on the updated local and international sanction lists. 

Appointment of a Compliance officer:

Organizations must appoint a compliance officer – a money laundering reporting officer (MLRO). The officer supervises the compliance process by ensuring the AML procedure is appropriately implemented and checking if organizations follow the due process of AML compliance to safeguard themselves against financial crime risks. Suppose the firms identify any suspicious activity or transaction. In that case, the MLRO must file a Suspicious Activity Report or Suspicious Transaction Report to the CBUAE, with a copy to the DFSA. 

AML Rulebook:

The DFSA issues an AML Rulebook to firms that contain modules regarding implementing the AML/CFT regulations within the DIFC. The rulebook guides the firms to implement the measures effectively by interpreting the legislation correctly and adopting a risk-based approach. So, the firms should be aware of the contents of the DFSA AML rulebook and adhere to the same diligently. 

The critical distinctions between federal AML requirements and that of DIFC

1. DFSA Rulebook includes “person issuing or providing services relating to Non-Fungible Tokens or Utility Tokens” as a DNFBP, unless-

  • The transaction (or interconnected transactions) related to the issue of NFTs, or Utility Tokens, is equal to or less than $15,000 in value, or
  • The person is providing technology-related support or advice to an issuer of the NFTs or Utility Tokens.

While any person conducting business activities in relation to Non-Fungible Tokens (NFTs) is considered generally treated as Virtual Asset Service Provider as per federal laws in line with the FATF Recommendations.

2. DFSA Rulebook also specifically provides that Real Estate Developers and Insolvency Firms would be construed as DNFBP.

3. Regulated entities operating in DIFC must have a Compliance Officer who is a UAE resident (except in the case of a registered auditor). It is not a condition as per federal AML Law. 

4. The minimum period prescribed for record keeping is six (6) years per DIFC regulations, while it is five (5) years per federal laws. 

5. AML Annual Return (for the period 1st August of the previous year to 31st July of the reporting year, to be filed by the end of September of each year) is the requirement under DFSA Rulebook for all the regulated entities operating in or from DIFC. It is in addition to the requirement of semi-annual report submission as per Cabinet Resolution No. (134) of 2025.

AML Regulation Enforcement by DFSA

Failure to comply with the AML/CFT laws by organizations falling within the ambit of the DIFC is subjected to investigations. The DFSA might ask for evidence such as account details and records and conduct interviews with the Compliance Officer and the senior management. It is mandatory to follow the rules as non-compliance will lead to the imposition of fines – violation of AML rules attracts a penalty between 10,000 to 1 million dirhams. Money launderers and predicate offenders can also be imprisoned for up to 10 years. 

Expert AML Assistance 

It is imperative to seek assistance from a top AML consultant to ensure effective compliance with AML/CFT obligations. AML UAE is one of the leading AML consultants in UAE that offer a wide range of AML compliance services such as AML/CFT policies, procedures, and controls documentation, AML Training, AML/CFT health check, AML software selection, assistance in setting up an in-house AML compliance department, Annual AML/CFT Risk Assessment Report, and regulatory reporting requirements.

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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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Accurate AML Compliance with KYC Automation

Accurate AML Compliance with KYC Automation

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Published On: 09/22/2022

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Last Reviewed On: 08/19/2026   |   Last Updated On: 08/19/2026

Accurate AML Compliance with KYC Automation

Know Your Customer of KYC, as we call it, is the fundamental criterion for starting a business relationship with a customer. Customer due diligence is a statutory obligation under Article 19(1)(b) of Federal Decree-Law No. 10 of 2025, with the detailed measures set out in Articles 6 to 15 of Cabinet Resolution No. 134 of 2025. A robust KYC process helps businesses comply with the AML rules and regulations and identify any discrepancies in the customers’ profiles at the initial stages of establishing a business relationship. It helps identify forged identities often used to place the illegal money through the legal system and hide their origin or source. But manually managing and implementing the KYC process can be complex and challenging, especially in the fast-evolving digital environment, where the outcome expected is precise and immediate. Digital transformation in AML compliance requires an hour as these processes must combat financial crimes-related challenges arising from identifying and verifying the customers and business partners. 

For Know Your Customer (KYC), businesses often depend on reliable external sources to verify and authenticate the information furnished by the customers. The onboarding process is deemed to be concluded when information submitted by the potential customer is screened/verified against the data made available by third parties. It includes the government agencies that manage the company registration and incorporation work and agencies involved in overseeing the credit scores and risk management. Such information is available and accessible in the public domain on their web products or via APIs. Businesses can access this valuable information via hard copies or digitally to ensure they have all the required information at their disposal when carrying out the KYC process. 

The KYC files consist of primary and secondary documents. The primary documents are the ones that act as supportive evidence from trustworthy independent sources. At the same time, the secondary information includes reporting of the compliance specialists that reveals the data analysis, interpretation, and the results derived from the analysis. 

Businesses need to liaise with such agencies to help them verify the authenticity of the documents furnished by individuals and entities proposing to establish a business relationship. It will help them carry out the due diligence process and ensure that they associate with only legit businesses with no criminal records or intention to get involved in money laundering activities. 

Most KYC process includes employees manually creating documents. Team collaboration in AML compliance depends on documents shared in drives and sent via email. These KYC files are shared and accessed, and the compliance team collaborates online to complete the KYC process. Earlier manual downloading of the KYC files was cumbersome, and KYC became an overwhelming process for both small and large designated organizations. 

Creating digital customer profiles with access to complete customer data helps businesses achieve full AML compliance. Digitization has streamlined the KYC process and made it more manageable and cost-effective. Now, with the help of technology dedicated to efficiency in the compliance processes, such as AML software, companies can complete the KYC process in a relatively short period with more effective and accurate results. They can offer a smooth onboarding process and an enhanced customer experience. 

Disadvantages of Manual KYC 

There are several disadvantages of manual KYC processes, which urge businesses to move towards digitization and create digital customer profiles. Collecting the customers’ information, organizing, and storing it manually is a burdensome task that leaves business organizations no time to focus on growth. Instead, they are tied up between the complex compliance requirements and fulfilling the basic needs of the KYC and due diligence for its customers. Let’s know why business organizations should reduce dependency on manual KYC drastically. 

Information gathering is a time-consuming task and therefore delays the customer onboarding process. It leads to a bad customer experience, involving too much correspondence between the parties, damaging the company’s reputation. 

Human errors are also a factor that makes companies consider minimizing dependencies on manual efforts. Errors can enable criminals to misuse an organization’s financial system and exploit the resource to launder illegal money. In addition, improper implementation of the policies does not yield the desired results and leads to discrepancies in the entire compliance process. Errors can jeopardize the whole compliance exercise and render the KYC process ineffective, which makes the organization more vulnerable in the hands of criminals.  

In such a scenario, businesses attract penalties and fines imposed by the government and the concerned authorities. Regulatory action is taken against firms that do not implement the KYC process diligently.  

Digitization and automation can help businesses streamline the KYC process, avoid all the problems mentioned above, and ensure AML compliance. 

Accurate AML Compliance with KYC Automation

KYC Automation

Integrating the AML software to make the KYC process more manageable, robust, and efficient would be the optimal suggestion. Digitizing the KYC process will ensure a digital customer profile that can be easily created, accessed, and stored, managed while collaborating with the compliance team. It will provide accurate results and help businesses detect any anomaly early in the compliance process, starting from customer onboarding. 

Automated KYC Verification

Automated KYC verification reduces the time taken to perform completeness checks and enables a world-class customer experience.

With real-time updates, the whole team is on the same page and can work effectively to combat money laundering and financing of terrorism. The KYC automation software unifies information and presents data in an easy-to-understand format helping the team analyze and derive accurate results. So, automating the manual KYC will help businesses implement the KYC procedures correctly and assist in accurate risk assessment and management. 

Manual KYC vs. Digital KYC

The best way to bring efficiency to the KYC and other AML compliance frameworks is to leverage technology that provides quick and accurate results and reduces the dependency on human resources. Manual processes are fast becoming redundant as the evolving technology is streamlining the KYC process and delivering results in a blink of an eye. So, businesses can free their workforce from manual and mundane tasks and instead direct them towards solving more complicated tasks, focusing on the growth of the business’s core operations.  

Social media has become a potent source of real-time information that companies can easily access anytime. Businesses can get the customers’ details from online sources and analyze the customers’ accounts digitally to arrive at the correct conclusion. 

With the updated and correct information, businesses can make informed decisions regarding the authenticity of the documents furnished for KYC. They can identify forgery of any kind during the onboarding process and avoid any mishap of financial crimes. 

KYC requires collecting and verifying customer data, which businesses monitor throughout the business relationship journey. Continuous monitoring helps detect changes in the customer profile. Creating and updating customer profiles manually is daunting; therefore, relying on technology and creating customer profiles digitally is advisable. With a digital profile, the compliance personnel can easily track all the customer data and compare it with the current profile to analyze changes. With continuous monitoring, businesses can detect any unusual customer behavior and immediately track any suspicious activity with the help of technology. Mapping the original customer profile with the updated profile with accuracy is possible only with technology.  

Often mergers and acquisitions and business expansions lead to ownership and management structure changes. Therefore, updated changes in the digital customer profile will help businesses analyze any change in the customer profile – such as the identification of the Ultimate Beneficiary Owner (UBO) or a customer who might have become politically exposed (PEP). It is noteworthy that the primary and secondary information is not helpful in isolation. Instead, it is interdependent, so the compliance team must depend on both to get a clear and better understanding of the KYC files and make informed decisions on establishing a customer relationship or executing any transaction. 

Manual KYC processes are tiring with no control over information and collection, slows down the entire KYC process. It is time-consuming and often characterized by human errors. 

Final Words

Using technology for AML compliance is the way forward for all businesses. Today, KYC automation software that works on AI brings the much-needed proactiveness and efficiency that companies need to comply with the ever-changing AML regulations. Automation with the help of AML software makes the KYC process more accurate and cost-efficient. It saves precious time for the organizations, which they can allocate to core business functions. Technology helps efficiently implement the AML policies and ensures 100% adherence to the AML laws.

Moreover, it reduces operational costs to a large extent by reducing human dependency on the completion of the KYC process and the occurrence of human errors. The technology makes data collection, storage, and retrieval quick, easy, and effortless, simplifying the AML compliance process. 

AML UAE is there to assist you in the KYC automation process by identifying an appropriate AML software to address your unique business requirements. 

Our timely and accurate AML consulting services

For your smooth journey towards your goals

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About the Author

Jyoti Maheshwari

CAMS, ACA

Jyoti has over 11 years of hands-on experience in regulatory compliance, policymaking, risk management, technology consultancy, and implementation. She holds vast experience with Anti-Money Laundering rules and regulations and helps companies deploy adequate mitigation measures and comply with legal requirements. Jyoti has been instrumental in optimizing business processes, documenting business requirements, preparing FRD, BRD, and SRS, and implementing IT solutions.

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The Role of Sanctions in Achieving International Peace and Security

Role of Sanctions

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Published On: 09/22/2022

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Last Reviewed On: 08/19/2026   |   Last Updated On: 08/19/2026

The Role of Sanctions in Achieving International Peace and Security

Sanctions are a form of control a country exercises to coerce another country, group of countries, individuals, or entities to change their behavior and policies and follow the international trade rules. It is an integral part of the AML process and KYC procedures.  

Sanction lists help to know which individuals, entities, and businesses are banned from trading. So, companies can make an informed decision regarding establishing and continuing a business relationship with the sanctioned entities or individuals. The sanction screening process helps businesses to know if their customers have been banned, and they can stop doing business with them to safeguard their reputation, protect their business interests, and avoid AML penalties.  

What are Sanctions? 

Sanctions are part of the foreign policy imposed by a country or groups of countries to ban another country, individuals/entities from doing business with them. Sanctions act as a coercion tool that governments use to pressure the prohibited countries/entities/ individuals to follow the rules and regulations and work in the interest of the global economy.

To give effect to these measures, regulated entities in the UAE are required to screen customers, beneficial owners and transactions against the UAE Local Terrorist List and the UN Security Council Consolidated List, and upon identifying confirmed name matchimplement asset freezing measures without delay. These obligations arise under Article 19(1)(e) of Federal Decree-Law No. 10 of 2025, implemented through Cabinet Resolution No. 74 of 2020 and the EOCN Guidance on Targeted Financial Sanctions (March 2026).

There are several forms of sanctions, and the most popular is the economic sanction that bans countries or groups of countries from doing business with sanctioned entities. Economic sanctions are measures one or more countries adopt against a business organization/government or group of nations to force them to follow international laws. Economic sanctions create financial difficulties for the banned countries and lead to substantial monetary losses. Sanctions can be unilateral and multilateral.

The former refers to when a government imposes a sanction on a person, entity, or nation – businesses operating in the sanctioned country will also be banned from doing business with them. The latter refers to when an international body such as the UN imposes sanctions. All the members of the UN will have to issue sanctions against the notified persons in their respective countries. So, the importance of the global sanction lists is no lesser than the local list of the respective country. 

Who Appears on the Sanction List? 

Sanctions are imposed on an individual – it may be a PEP, a business head, a criminal, or a terrorist. Sanctions may also be issued against the entity or a group of people – may be a terrorist or criminal organization. Sanctions are also issued against countries. It prohibits businesses from conducting transactions with persons or enterprises operating in or from the sanctioned country. 

Sanctions prohibit different activities, such as trade restrictions and banning commercial activities. It is against the law to do business with a sanctioned entity. So, as a part of its AML compliance and KYC process, a company must verify sanction entities with a proper sanction screening process. 

What are sanctions lists?

Sanction lists mention the sanctioned entities on which unilateral and multilateral sanctions have been imposed. It flags individuals, entities, and countries that pose a high risk to a business and the world economy. It helps to protect a business from being misused for or vulnerable to money laundering and terrorism financing. Several global bodies, such as the EU, OFAC, and the UN, impose sanctions and issue a detailed listing of the same. The sanctioned entities or individuals have a higher probability of committing financial crimes. 

But it is pertinent to note that the sanction lists are updated regularly to accommodate the changes in the current political and economic scenario. It is important to note that businesses keep track of the frequent listings and de-listings made in the sanction lists and keep themselves updated with the latest sanctions. 

Non-compliance in Sanction Screening 

Non-compliance in the sanction screening process leads to paying fines and huge penalties. Failure to follow the sanction screening rules also leads to imprisonment for a considerable term. Apart from the penalties, non-compliance leads to reputational damage, negatively impacting the goodwill of the business earned over the years. 

The diligence required in sanction screening

It is advisable to adopt a proactive compliance approach and conduct due diligence based on the business’s risk appetite and the customer’s potential risk. It will prevent risks of noncompliance. Integrating a practical compliance framework into the system is the best practice for an efficient approach toward compliance with AML rules, KYC, and sanction screening. Also, businesses must keep themselves updated with the revised guidelines and regulations and conduct due diligence accordingly.

With a good software solution, a company must bother about the AML compliances, where the screening and other compliance processes would be automated. It will keep the business ahead of the curve by following all the latest guidelines in AML compliance and conducting the sanction screening in almost real-time. 

How does Sanction Screening Work? 

In sanction screening, businesses have to screen the customers’ database/profile against the individuals/entities and countries appearing on the sanction list issued by the local government and international bodies. Basis the sanction searches, a business will screen its customers on the global and local lists to check whether any of its customers are named on the sanction list. The objective is to conduct a thorough screening to help them comply with the sanction rules and regulations and protect the business from being exploited by the money launderers. It also helps in protecting the company’s reputation. Today, businesses rely on software solutions to automate the sanction screening process and get quick and accurate results. 

Manual sanctions screening processes are time-consuming and cumbersome, with the possibility of human errors, making the whole exercise futile. It results in the wastage of precious resources and time. So, it is best to rely on technology to bring in the much-needed efficiency and higher accuracy in the results, saving time and cost. 

Role of Sanctions

Why should automated sanctions screening be preferred?

With technology and digitization spreading their wings across different spans of businesses, it is recommended to deploy an advanced tech-based solution for the sanctions screening process. There are several advantages of the sanction screening software. The software will automatically run quick and accurate searches in the local and global sanction lists and quickly identify if any of the customers are sanctioned. Technology will automate the process, bring more efficiency, and speed up the customer onboarding decision-making process.

Ease of Search

The software will run quick searches in the local and international sanction lists and deliver fast results. It helps the business make swift, informed decisions that will help them identify companies appearing on the sanction lists and whether to conduct business transactions with them or not.

Accuracy

Relying on the software will eliminate human errors and provide more precise outcomes. 

Integration with Existing Systems

The software solution integrates with the current in-house AML systems and increases the existing solution’s capability. Business organizations get a 360-degree view of their customer’s profiles and correctly determine the true identities of the customers and the associated risks. 

Updated Information

The software will conduct searches based on the latest and revised guidelines in the sanction screening rules and updated lists without businesses manually tracking the amendments. 

Additional Tip for Sanction Screening:

It is highly suggested to develop a robust AML compliance framework in the organization and adopt a proactive approach toward sanctions screening. So, during the screening process, businesses should search for aliases, and name variations, including and excluding middle names. Also, match the customers’ information based on the date of birth, middle name, nationality, ID number, etc.  

Final Words

It is mandatory to follow the sanction screening rules and comply with the AML regulatory compliances. Sanction monitoring can be effective and result-oriented with the help of technology that automates the AML compliance process. It helps to keep in sync with the latest updates in new listings and de-listings so they have updated lists and can correctly screen their customer database and keep it up to date. It allows businesses to avoid penalties and make informed decisions by not doing business with a sanctioned entity, saving monetary costs and reputational damages. 

AML UAE

AML UAE is one of the leading AML consultancies in the region, offering unparalleled services in AML compliance and advisory support. We help you identify the most optimal AML software for your business and sanction monitoring solutions. Deployment of this technology will help you effortlessly screen customers’ profiles against local and international sanctions. Get assistance with the KYC and sanctions screening process and achieve 100% AML compliance.

Our timely and accurate AML consulting services

For your smooth journey towards your goals

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About the Author

Jyoti Maheshwari

CAMS, ACA

Jyoti has over 11 years of hands-on experience in regulatory compliance, policymaking, risk management, technology consultancy, and implementation. She holds vast experience with Anti-Money Laundering rules and regulations and helps companies deploy adequate mitigation measures and comply with legal requirements. Jyoti has been instrumental in optimizing business processes, documenting business requirements, preparing FRD, BRD, and SRS, and implementing IT solutions.

Reach Out to Jyoti