MOEC/AML/0012023 Updated list of high-risk jurisdictions and jurisdictions under increased monitoring and counter-measures to be applied by DNFBPs

UAE Ministry of Economy’s circular on the updated list of high-risk jurisdictions

With the revision in the FATF’s list of the countries subject to increased monitoring and list of high-risk countries amended by UAE’s National Anti-Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations Committee (NAMLCFTC), the Ministry of Economy has issued a Circular bearing No. MOEC/AML/001/2023.

The Ministry has addressed the circular to the following Designated Non-Financial Businesses and Professions (DNFBPs):

The Circular provides that all the DNFBPs must revise the AML/CFT program, re-evaluating the appropriateness of the AML/CFT measures to manage the risk while establishing a business relationship or transacting with a customer from high-risk jurisdictions.

Counter-measures to be applied by DNFBPs while dealing with high-risk jurisdictions and jurisdictions under increased monitoring

DNFBPs are supposed to apply various counter-measures while dealing with high-risk jurisdictions and jurisdictions under increased monitoring.

Countries under Grey List

With regard to Grey listed countries, FATF’s list of jurisdictions subject to increased monitoring, the Ministry provides that the DNFBPs apply Enhanced Customer Due Diligence (EDD) measures. Generally, to manage the increased money laundering or financing of terrorism risks, the DNFBPs must apply additional measures like checking the legitimacy of the source of funds and source of wealth. Further, the DNFBPs should also insist on getting the first payment from such customers through their own accounts with a financial institution subject to similar due diligence standards.

Please note that no business relationship can be established, or a transaction is executed with a customer from these countries without the prior approval of the senior management.

Countries under Blacklist

Please note that no business relationship can be established, or a transaction is executed with a customer from these countries without the prior approval of the senior management.

The measures mentioned above are in addition to implementing the Targeted Financial Sanctions (TFS), following the United Nations Security Council’s Resolutions and UAE’s Cabinet Decision No. (74) of 2020, i.e., restriction on onboarding any customer designated under any Sanctions Lists (UNSC Consolidated List and UAE Local Terrorist List).

Business relations and transactions with high-risk jurisdictions must be subject to more rigorous and frequent monitoring to detect and report suspicious transactions. Note that the suspicious reporting involving customers from Blacklisted countries must be done using the following reports available on the goAML portal:

  • High-Risk Jurisdiction Report or High-Risk Country Transaction report (HRC), or
  • High-Risk Jurisdiction Activity Report or High-Risk Country Activity report (HRCA).

Know more about HRC and HRCA

The circular is aligned with the provisions of Cabinet Decision No. (10) of 2019 and the countermeasures recommended by the UAE’s National Anti-Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations Committee (NAMLCFTC).

To ensure adequate compliance with AML/CFT framework, the DNFBPs must regularly check the list of high-risk countries on the website of NAMLCFTC and stay updated.

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