Webinar on Mastering Regulatory Reporting: A Deep Dive into SAR/STR Compliance

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Webinar on Mastering Regulatory Reporting: A Deep Dive into SAR/STR Compliance

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Exclusive Webinar on Mastering Regulatory Reporting: A Deep Dive into SAR/STR Compliance

Date: 7th January 2024

Time: 11:00 AM to 12 Noon (GST)

Venue: Online

We are delighted to present a unique opportunity for you to gain invaluable insights about Suspicious Activity Report/Suspicious Transaction Report (SAR/STR) Compliance under UAE AML Laws from our esteemed AML expert, CS Dipali Vora

Join us for a compelling webinar where she will guide you through AML framework in UAE, different types of reports under UAE AML Laws, and in-depth details of SAR/STR reporting.

Key Highlights:

Types of Reports under UAE AML Laws: Explanation regarding various types of reports and different instances for filing these reports.

Understanding Suspicious Transaction: Delve into the definition of suspicious transaction and difference between suspicious transactions and suspicious activities.

Recognition of Red Flags: Learn how to identify potential indicators of suspicious transactions and suspicious activities.

Understanding SAR and STR: Delve into the definitions and significance of suspicious activity report and suspicious transaction report, its reporting mechanism, and consequences of non-compliance.

Actionable post filing SAR/STR with FIU: How to manage business relationship with customer post filing an SAR or STR with FIU.

Best Practices: Learn the best practices of reporting suspicions and maintaining an effective compliance culture.

Why Attend?

By participating you will:

  • Enhance your understanding of reporting obligations.
  • Stay updated on regulatory requirements.
  • Learn practical strategies for identifying and addressing suspicious activities.

Register now to secure your spot for this exclusive event! Don’t miss this chance to learn from an industry expert and ensure the compliance requirements related to SAR/STR.

Stay ahead in the fight against financial crime. Join us for this insightful webinar and empower yourself with the knowledge to recognize and report suspicious activities or suspicious transactions effectively. Register now!

What action should be taken if any match is identified against the OFAC List?

The UAE regulations require the regulated entities to perform sanctions checks against the UNSC Consolidated List and the UAE Local List. In case of any matches identified against other international sanctions lists, the controls are to be applied considering the business’s risk appetite and the risk-based approach adopted by the entity. It is important to note that for entities dealing with customers and suppliers from the USA, it is advised to reject the business relationship when identified as a match with the OFAC List and submit a SAR/STR on the goAML Portal.

Further, entities operating in jurisdictions like ADGM & DIFC must conduct screening against international sanctions lists like OFAC and EU, depending on the business profile, reject the customer and furnish SAR/STR with the FIU in case of matches.

The UAE AML regulations provide that the DNFBPs must report the identified ML/FT suspicions to the FIU, without any delay. Thus, it is suggested that the alerts be attended to and addressed as soon as possible and that the SAR/STR be immediately submitted to the goAML portal once the suspicion is confirmed and the decision to report the same is made.

The entity must submit a Suspicious Activity Report (SAR) when any ML/FT risk indicators are observed at the initial stage of customer interaction. The reporting of ML/FT suspicions should be done irrespective of the status of the transactions – whether the transaction is completed, in progress or not yet initiated (attempted transaction by the proposed customer relationship).

It is suggested to seek additional details, independently or from customers (without tipping off), to determine whether it is a confirmed or false match. Yet, if it cannot be concluded, then this would be treated as a Partial Name Match where the decision cannot be made due to lack of key identifiers, and you should file a Partial Name Match Report (PNMR) on the goAML portal. Here, the business relationship with such a person must be suspended until you receive instructions from the authorities.

To successfully register on the goAML portal, you can refer to our YouTube video on the subject https://www.youtube.com/watch?v=H84kv3R6njs or refer to our eBook – https://amluae.com/goaml-registration-guide-ebook/, which provides the step-wise process to be followed, the documents to be furnished, etc.

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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

Video on Factors for AML Enterprise Wide Risk Assessment

Video on Factors for AML Enterprise Wide Risk Assessment

Video on Factors for AML Enterprise Wide Risk Assessment

Video on Factors for AML Enterprise-Wide Risk Assessment

The Enterprise Risk Assessment (EWRA)/ Business Risk Assessment is vital in ensuring AML compliance.

The reporting entities (Financial Institutions, DNFBPs and VASPs) shall conduct ERWA considering the relevant risk factors, their likelihood of occurrence, and countermeasures deployed.

It should help determine the level of risk exposure of the company. Based on EWRA, the entity needs to design its AML/CFT policies and procedures and lay down controls to counter the risks of ML/TF and remain compliant with AML regulations. The EWRA takes into account qualitative and quantitative aspects.

This video helps in understanding various risk factors:

  • Customer risk
  • Geographic risk
  • Product/ Services risk
  • Transaction risk
  • Delivery channel risk
  • Technology risk
  • Other relevant risk factors depending on the nature and size of the business.

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Video on Independent AML Audit

Video on Independent AML Audit

Video on Independent AML Audit

Video on Independent AML Audit

To safeguard the reporting entities (Financial Institutions, DNFBPs and VASPs) from financial crime risks and to remain compliant with AML requirements, an AML Audit must be conducted independently by competent personnel on a periodic basis to ensure that the AML Program of the entity is consistent with AML rules and regulations.

AML Audit is entirely different from a financial audit of the books of accounts. The Independent AML Audit verifies the entity’s AML/CFT compliance framework.

The audit helps to identify gaps in the existing AML Program, detect loopholes and recommend best practices to bridge the gaps. To bridge the gap, the AML Auditor may recommend the implementation of additional controls, developing or enhancing the AML training programs, and adopting new technological solutions to strengthen the AML capabilities. Further, the AML auditor must be aware of the latest regulatory amendments and understand the AML obligations of the particular entity. This video explains:

  • What is an Independent AML Audit?
  • Why is it needed?
  • Who can perform an independent AML audit?

Chapters:

  • 0:00 Introduction to Independent AML Audit
  • 0:47 What is an Independent AML Audit
  • 1:36 Why an Independent AML Audit is necessary
  • 1:54 Reasons to carry out Independent AML Audit
  • 3:09 Who can conduct AML Audits
  • 4:08 Conclusion and regards

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Video on Suspicious Activity vs. Suspicious Transaction

Video on Suspicious Activity vs. Suspicious Transaction

Video on Suspicious Activity vs. Suspicious Transaction

A Suspicious Activity Report (SAR) differs from Suspicious Transaction Report (STR) mainly due to elements of suspicious activity or transaction. SAR comes into picture where suspicious activity is identified, whereas STR comes into picure where suspicious transaction is identified.

According to AML UAE regulations, the reporting entities (Financial Institutions, DNFBPs and Virtual Asset Service Providers) must comply with reporting requirements with FIU on the goAML portal. Based on the red flags identified concerning any suspicious activity/ transaction, the entities must report the same to FIU on the goAML portal by filing a Suspicious Activity Report (SAR)/ Suspicious Transaction Report (STR).

SAR means to report any suspicious activity in case of attempted or unexecuted transactions before establishing a relationship with the customer. In contrast, STR means to report any suspicious transaction when the transaction has already been executed, or funds transfer has been initiated or concluded, even if the supply of goods/ services is pending.

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Video on Role of Senior Management towards AML

Video on Role of Senior Management towards AML

Video on Role of Senior Management towards AML

Video on Role of Senior Management towards AML

The reporting entities (financial institutions, DNFBPs, and VASPs) must have a robust program in place to ensure compliance with AML rules and regulations. Ensuring the same requires the support of senior management, which plays a vital role in AML compliance.

The reporting entities must design and implement AML Policies and Procedures to ensure compliance with all the mandatory requirements. One of Senior Management’s key responsibilities is appointing a Compliance Officer. The Senior Management has the following roles and responsibilities:

  • Appointment of Compliance Officer
  • Approving AML Policy
  • Approval to onboard high-risk customer
  • Appointment of an Independent AML Audit Auditor
  • Oversight of Third Parties
  • Reviewing AML Report
  • AML Issues fixing
  • Non-Tolerance and leading

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Video on goAML Reporting requirement in UAE

Video on goAML Reporting requirement in UAE

Video on goAML Reporting requirement in UAE

Video on goAML Reporting requirement in UAE

Pursuant to UAE AML Rules and Regulations, Financial Institutions, DNFBPs, and Virtual Asset Service Providers must register on the goAML Portal to comply with timely reporting requirements with the FIU and the concerned supervisory authority.

The reporting entities are required to submit various reports on the goAML portal, depending upon the nature of the transaction. This video will help you understand various reports that must be filed under  UAE AML regulations.

  • Suspicious Transaction Report (STR)
  • Suspicious Activity Report (SAR)
  • Additional Information File without Transaction (AIF) 
  • Additional Information File with Transaction/s (AIFT) 
  • Request for Information without Transactions (RFI) 
  • Request for Information with Transaction/s (RFIT) 
  • High-Risk Country Transaction Report (HRC)
  • High-Risk Country Activity Report (HRCA)
  • Dealers in Precious Metals and Stones Report (DPMSR)
  • Real Estate Activity Report (REAR)
  • Confirmed Name Match Report (CNMR)
  • Partial Name Match Report (PNMR)

Chapters:

  • 0:00 Introduction on goAML Reporting Requirement in UAE
  • 0:24 Reports to be submitted by reporting entities
  • 1:12 Suspicious Transaction Reports (STR) and Suspicious Activity Report (SAR)
  • 1:54 High-Risk Country Transaction Report (HRC) and High-Risk Country Activity Report (HRCA)
  • 2:25 Dealers in Precious Metals and Stones Report (DPMSR)
  • 2:52 Real Estate Activity Report (REAR)
  • 3:15 Confirmed Name Match Report (CNMR) and Partial Name Match Report (PNMR)
  • 4:19 Short brief goAML Reporting Requirement

Related Infographics:

Related Templates:

Related Laws, Guidelines, Rules, and Regulations:

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Determining the Customer’s Risk Profile

customer risk profile

Determining the Customer's Risk Profile

Determining the Customer's Risk Profile

Based on KYC/ KYB and screening, the reporting entities (Financial Institutions, DNFBPs and Virtual Asset Service Providers) must assess the risk associated and assign an appropriate risk rating to the customer.

The reporting entities shall assess the Customer Risk by classifying the customer risk profile depending upon the risks involved as unacceptable, high, medium, or low. The higher the risks, the more stringent controls must be in place to mitigate such risks.

In case customers are classified as “high-risk”, the reporting entities must apply Enhanced Due Diligence (EDD) measures. The following parameters can be considered while doing risk profiling:

  • Customer risk
  • Transaction risk
  • Customers Jurisdiction/ Geographical risk
  • Product/ Service risk
  • Delivery channel-related risk
  • Other relevant factors.

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Essential Element of Sanctions Compliance in UAE – Filing Partial Name Match Report

Video on Filing Partial Name Match Report

Video on Filing Partial Name Match Report
Essential Element of Sanctions Compliance in UAE

Video on Filing Partial Name Match Report - Essential Element of Sanctions Compliance in UAE

The reporting entities (Financial Institutions, DNFBPs and Virtual Asset Service Providers) must comply with goAML reporting requirements with the Financial Intelligence Unit.

The reporting entities must screen their new/ existing customers based on the UNSC consolidated list and UAE local terrorist list before onboarding or carrying out any occasional transaction.

Based on sanction screening, if the entities find a potential match with the sanction list, then Reporting entities must suspend the transaction and file a Partial Name Match Report (PNMR) on the goAML portal.

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Ultimate Beneficial Owners: Unveiling the real names

Video on Ultimate Beneficial Owners Unveiling the real names

Video on Ultimate Beneficial Owners: Unveiling the real names

Video on Ultimate Beneficial Owners: Unveiling the real names

The key element of Customer Due Diligence before onboarding corporate customers is to identify ultimate Beneficial Owners (UBO) and unveil their true identity to fight against money laundering and terrorist financing.

If UBO pertains to high risk, then the entity will also be treated as high risk, and Enhanced Due Diligence is to be conducted for both. UBO can only be a natural person. The following qualifies as UBO:

  • If a natural person has 25% or more ownership interest in an entity through direct or indirect shareholding
  • If a natural person holds 25% or more of the voting rights in an entity
  • If a natural person has the right to appoint or dismiss a majority of the managerial persons in the entity
  • If there is any other way by which a natural person exercises ultimate control over the entity
  • If UBO cannot be determined, then a natural person holding a senior managerial position in the entity would qualify as a UBO

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Exclusive Webinar on Customer Risk Assessment

Customer risk Webinar

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Exclusive Webinar on Customer Risk Assessment

 

PAST EVENT

🌟 Join Our Exclusive Webinar on Customer Risk Assessment! 🌟

📅 Date: 2nd December 2023

⏰ Time: 11:00 AM to 12 Noon (GST)

📍 Venue: Online

🌟 We are excited to bring you a unique opportunity to delve into the intricacies of Customer Risk Assessment with our esteemed AML expert, Dipali Vora. Join us for a compelling webinar where she will guide you through the critical aspects of assessing and categorizing customers based on their risk profiles.

🔍 Key Highlights:

✅ Expert Insights: Learn from industry leaders who have mastered the art of customer risk assessment. Gain invaluable insights into identifying, evaluating, and mitigating risks effectively.

✅ Best Practices: Discover the latest strategies and best practices to fortify your business against potential threats. Our experts will share actionable tips to implement robust risk assessment protocols.

✅ Case Studies: Benefit from real-world case studies illustrating successful customer risk assessment strategies and the consequences of inadequate assessments.

🔒 Why Attend?

By participating in this webinar, you will acquire practical insights to strengthen your Customer Risk Assessment processes, align with regulatory requirements, and mitigate risks effectively.

📝 Register now to secure your spot for this exclusive event! Don’t miss this chance to learn from an industry expert and ensure your customer risk assessment process aligns with international best practices.

📞 For inquiries, please drop us a mail: info@amluae.com

🌐 Stay ahead of evolving AML practices in the UAE. Join us for this enlightening webinar and empower your organization to effectively manage customer risks. Register now! 🌟

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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