ML/FT Risk Assessment

Section 1
Sub-Category 1.1
Sr. Q No. Question

1 1 Please select the registration authority?

Please select your establishment's legal form, update the trade license
2 2
number in comment box and attach your legal entity's Trade License?
3 3 Please select your sector from the below list ?

Select the services you provided to your clients during the reporting period:
4 4 - Please note that on selection of "None of the above" confirmation letter to
be attached

Does the company have a bank account in the UAE? If yes, please provide
5 5
the bank name
Did a bank or any other financial institution decide to close an account or
6 6
end an ongoing relationship with your establishment?
If yes, please provide the name of the bank or financial institution
7 7

If yes, Please provide the rationale for the account closure or ending the
8 8 relationship

If yes, please attach the account closure letter or email.

9 9

Did a bank or financial institution refuse to open a new account or enter

10 10
into a new relationship with your establishment?
If yes, please provide the name of the bank or financial institution
11 11

If yes, please provide the rationale for refusing to open an account or

12 12 establish a relationship with your establishment

Please provide and attach your establishment full ‘shareholding structure’

13 13
up to the Benefical Owners, including beneficiaries of trusts if any

Does your establishment has any other DNFBP affiliates in the UAE under
14 14 the MOE’s supervision. If so, a copy of the affiliate’s trade licenses should be
attached.

Section 2
Sub-Category 2.1A
Q No. Question
15 1 Does your company have a complex ownership structure ?
16 2 Is your establishment a member of a group of companies ?
 Total number of employees in your establishment (Please provide the exact
17 3
value in comment box)
18 4 What is the total number of branches for your establishment?

Sub-Category 2.1 B
Q No. Question
Does your establishment hold any Power of Attorney (POA) or
19 1
authorizations arrangements with clients?
If yes, please describe the nature, scope, and number of the POA
20 2 agreements or authorizations.

Does any individual within your establishment hold a Power of Attorney

21 3
(POA) or authorization to act on behalf of clients?
If yes, provide details on the individuals, the extent of their authority, and
22 4 the number of such authorizations.

Sub-Category 2.1 C
Q No. Question
The number of properties your entity acted as broker or agent during the
23 1 assessment period (buying and selling)? (Please provide the exact value in
comment box)
Provide the total value of the properties your entity acted as broker or
24 2 agent during the assessment period (buying and selling)? (Please provide
the exact value in comment box)

Sub-Category 2.1 D
Q No. Question
25 1 Do you have any clients who are acting as trustees for a trust?
Provide the number of clients who are trusts or legal arrangements in your
26 2
establishments?
Provide the value of transactions for trusts or legal arrangements clients in
27 3
your establishments? (Please provide the exact value in comment box)

Sub-Category 2.2 A
Q No. Question
 What is your establishment's total turnover (in AED) for the last reporting
period for active clients? (Only for the below activities)(Please provide the
exact value in comment box)1. Broker and Real Estate Agents Service
2. Dealing in Precious Metals and Precious Stones in cash equal to more
than AED 55,000 (In a single cash transaction or several transaction that
appear interrelated)
3. Prepared, Conducted or Executed financial transaction for customer in
purchasing & selling real estate
4. Management of funds owned by the customer
5. Management of bank accounts, saving accounts or securities account
6. Organizing contributions for the establishment, operation or
management of companies
7. Creating, operating or managing legal persons or Legal Arrangements
28 1
8. Prepared, Conducted or Executed financial transaction for customer in
Selling and buying commercial entities
9. Acting as an agent in the creation or establishment of legal persons
10. Working as or equipping another person to serve as director or secretary
of a company, as a partner or in a similar position in a legal person
11. Providing a registered office, work address, residence, correspondence
address or administrative address of a legal person or Legal Arrangement
12. Performing work or equipping another person to act as a trustee for a
direct Trust or to perform a similar function in favour of another form of
Legal Arrangement
13. Working or equipping another person to act as a nominal shareholder in
favour of another person

What is your establishment's total number of business transactions for the

29 2
last reporting period?
What is the total number of clients your establishment have?
30 3
31 4 Provide the total number of active clients during the reporting period ?
Does your establishment have foreign clients ?
32 5

If yes, provide the total numbers of foreign clients.

33 6

Do you have Natural Persons (individual) as clients which includes residents

34 7 and non-residents?

If yes, provide the total number of resident natural persons (Individual)

35 8 clients.

If yes, provide the total number of Non-resident natural persons (Individual)

36 9 clients.
 If yes, provide the total transaction values of resident natural persons
37 10 (Individual) clients. (Please provide the exact value in comment box)

If yes, provide the total transaction values of Non-resident natural persons

38 11 (Individual) clients. (Please provide the exact value in comment box)

Do you have corporate clients (which includes domestic and international)

39 12 in your client list?

If yes, provide the total number of domestic corporate clients

40 13

If yes, provide the total number of International corporate clients

41 14

If yes, provide the total transaction values of domestic corporate clients.

42 15 (Please provide the exact value in comment box)

If yes, provide the total transaction values of International corporate clients.

43 16 (Please provide the exact value in comment box)

Does your establishment have corporate clients that have beneficial owners
44 17 who are non-residents? If yes provide the number of clients

Proivde the number of customers who conduct business that is exposed to

PF (proliferation finance) activities, or engage in transactions exposed to PF
45 18
activities?

Sub-Category 2.2 B
Q No. Question
Number of clients onboarded through face to face ?
46 1

Provide the percentage of clients using face to face channels. (Please

47 2 provide exact % in comment box)

Number of clients onboarded through non face to face ?

48 3

Provide the percentage of clients using Non face to face channels

49 4

Sub-Category 2.2 C
Q No. Question
Does your establishment have Politically Exposed Persons (PEPs) as
50 1 customers/clients? If yes, provide the total number of PEPs
 Does the establishment have Domestic Politically Exposed Persons as
51 2 clients? If yes, provide the number of domestic PEPs

Does the establishment have Foreign Politically Exposed Persons as clients?

52 3 If yes, provide the number of foreign PEPs

Sub-Category 2.2 D
Q No. Question
Do you rely on a third party to undertake your CDD measures?
53 1

Number of clients onboarded relying on third party CDD measures

54 2

If yes, select the nationality of onboarded clients through third-party from

the list.If the required countries are two or more /not listed, please select
55 3
Not applicable option and update the country name in the comment box.

If yes, how many such clients are active still?

56 4

Number of third parties through POA or authorisation acting on behalf of

57 5 clients (individual or entities) ?

Sub-Category 2.3 A
Q No. Question
Total number of products or services provided using emerging
58 1 technologies ?

Provide the total value of transactions provided through emerging

59 2 technologies. (Please provide the exact value in comment box)

Sub-Category 2.3 B
Q No. Question
Total number of products/service provided through third parties(online
60 1 platforms, digital channels, .etc) in your establishment?

Number of clients serviced through face to face channel ?

61 2
 Provide the percentage of clients using face to face channels. (Please
62 3 provide exact % in comment box)

Number of clients serviced through non face to face channels ?

63 4

Provide the percentage of clients using non face to face channels

64 5

Select the payment method you accepts

65 6

Sub-Category 2.4 A
Q No. Question
Do you have any branches/subsidiaries, representative offices, or primary
66 1 operations outside UAE?

Sub-Category 2.4 B (No Section for 2.4B)

Q No. Question
1

Sub-Category 2.4 C
Q No. Question
Do you have clients from High-risk countries?
67 1

If yes, provide the total number of clients from High-risk countries

68 2

If yes, provide the total value of transactions from High-risk countries

69 3 clients. (Please provide the exact value in comment box)

Total number of Transactions with beneficiary or originator domiciled in a

country with weak implementation of UNSCR obligations or FATF standards
70 4
or a weak export control regime (FATF)

Sub-Category 2.4 D
Q No. Question
Does your entity identified that any of your clients (entities) are owned or
operated by or on behalf of DPRK/Iran or dual citizens of DPRK/Iran or
71 1
DPRK/Iran entities

Do you have clients / UBOs of clients who are nationals of the following
72 2 countries? Iran, North Korea, Myanmar

If yes, Total number of transactions who are national from Iran, North
73 3 Korea, Myanmar
 If yes, Total Value of transactions who are national from Iran, North Korea,
74 4 Myanmar. (Please provide the exact value in comment box)

Do you have any customers that are the subject to international sanctions,
such as targeted financial sanctions (TFS), UAE, OFAC, UN and EU restrictive
75 5
measures?

Sub-Category 2.5 A
Q No. Question
Do you act as an agent or broker for purchase and sale of properties outside
76 1 UAE ?

If yes, Provide the number of transactions done within UAE

77 2

If yes, Provide the total value of payment done within UAE. (Please provide
78 3 the exact value in comment box)

If yes, Provide the number of transactions done from any other country
79 4 other than UAE

If yes, Provide the total value of payment done from any other country
80 5 other than UAE. (Please provide the exact value in comment box)

Sub-Category 2.5 B
Q No. Question
 Does your business or profession perform any of the following activities?
(Please select all that apply and provide more details on the selected items
other than not applicable option), 1- Provide products and/or services to
entities (including states and state-owned entities) and individual nationals
or residents of high-risk PF states, their relatives or known associates, 2-
Provide products and/or services to diplomatic or official personnel, their
relatives or known associates including from the DPRK or Iran, 3- Engage in
the production, manufacturing, trading or facilitation of PF-sensitive and/or
Dual-Use goods, 4- Engage in the import or export or facilitation of import
81 1 or export of goods from high-risk PF states such as Iran and North Korea, 5-
Act as nominee director or nominee shareholder for companies or
individuals from high-risk PF states such as Iran and North Korea, 6- Settle
business or professional transactions in cash in your name, the name of
your company or on behalf of third parties, 7- Settle business or
professional transactions in gold, jewelry and other precious metals and
stones in your name, the name of your company or on behalf of third
parties, 8-Conduct real estate transactions with individual nationals or
residents of high-risk PF states, their relatives or known associates
,9- Not applicable.

Does your company hold assets under management/custody on behalf of

clients ? If yes, please proivde the Maximum value of the assets during the
82 2
reporting period. (Please provide the exact value in comment box)

Do you have clients with the trust legal form ? If yes, please select the type
83 3 of trusts your clients are involved.
1- Family trusts, 2- Charitable trusts, 3- Business trusts, 4- Not applicable
If yes, provide the number of the clients
84 4

If yes, provide the total value of the transactions. (Please provide the exact
85 5 value in comment box)

Provide the total value of the transactions if any of the products/services

86 6 offered to non-customers. (Please provide the exact value in comment box)

Does your business or profession use any of the following financial

87 7 instruments in the course of your business? (Please select all that apply):

Do you organize contributions for the establishment, operation or

8
management of companies owned by your clients ?
Do you provide services related to creating, operating or managing
11
legal persons or legal arrangements.
14 Do you provide services related to selling and buying commercial
entities.
Do you provide service related to Fractional CFO (Chief Financial
17
Officer) to any of your clients
19 Do you provide service related to Liquidation to any of your clients
22 Do you provide service related to Acquisition to any of your clients
Sub-Category 2.5 C (There is no 2.5C Section)
Q No. Question
1 Do you manage funds owned by your customer.
Do you manage bank accounts, saving accounts or securities
4
accounts on behalf of your customers ?

Sub-Category 2.5 D
Q No. Question
Do you act as an agent or broker for non residents customers purchase and
88 1 sale of properties in UAE ?

If yes, Provide the number of clients within UAE

89 2

If yes, Provide the total value of transactions done within UAE. (Please
90 3 provide the exact value in comment box)

If yes, Provide the number of clients from any other country other than
91 4 UAE

If yes, Provide the total value of transactions done from any other country
92 5 other than UAE. (Please provide the exact value in comment box)

Sub-Category 2.5 E (There is No 2.5E Section)

Q No. Question
1

Sub-Category 2.5 F
Q No. Question
93 1 Do you deal in physical cash transactions ?
94 2 Total number of physical cash transactions
Total value of physical cash transactions. (Please provide the exact value in
95 3 comment box)

Total number of physical cash transaction below 55,000 AED

96 4

Total value of physical cash transaction below 55,000 AED. (Please provide
97 5 the exact value in comment box)

Provide number of deals you acted as a broker or agent which involved

physical cash payments between the buyer and seller above 55,000 AED ?
98 6
(single or multiple related transaction)
 Provide the Total value of deals you acted as a broker or agent which
involved physical cash payments between the buyer and seller above
99 7 55,000 AED ? (single or multiple related transaction) (Please provide the
exact value in comment box)

Do you prepare, conduct or execute financial transactions for your

8
customers for purchase and sale of real estate ?

Sub-Category 2.5 G
Q No. Question
Did your establishment accept any virtual assets as payments during the
100 1 reporting period ?

If yes, provide the total number of the transactions

101 2

If yes, provide the total value of the transactions in AED.(Please provide the
exact value in comment box) (Please provide the exact value in comment
102 3
box)

Provide the names of the virtual assets accepted.

103 4

Provide number of deals you acted as a broker or agent which involved

virtual assets as a payment method between the buyer and seller ? (single
104 5
or multiple related transaction)

Provide the Total value of deals you acted as a broker or agent which
involved virtual assets as a payment method the buyer and seller ? (single or
105 6 multiple related transaction) (Please provide the exact value in comment
box)

Section 3
Sub-Category 3.1A
Q No. Question
Does your establishment appoint a Compliance Officer?
106 1

Is the compliance officer is your own employee or is it outsourced or third-

107 2 party ?

If it is outsourced or third party, provide the name of the company

108 3

Location of the entity (outsourced/third party). If the required countries are

two or more /not listed, please select Not applicable option and update the
109 4
country name in the comment box.
 What is the total years of experience of the Compliance Officer in
110 5 AML/CFT/CPF?

Does the Compliance Officer have any professional AML/CFT/CPF

111 6 qualifications?

Does the Compliance Officer have the authority and independence to

112 7 perform his duties?

Does the Compliance Officer performs any other responsibilities or duties?

113 8

What is the reporting line of the Compliance Officer ?

114 9

Does the compliance officer ensure compliance with the AML/CFT/CPF

115 10 policies and procedures of the establishment?

Does your Establishment has a backup resource/employee in case of the

116 11 Compliance Officer is absent ?

Total number staffs in the compliance department

117 12

Have you outsourced any of the Compliance Officer responsibilities ?

118 13

If yes, provide the name of the company

119 14
Location of the entity (outsourced). If the required countries are two
120 15 or more /not listed, please select Not applicable option and update the
country name in the comment box.
Does the compliance officer prepare periodic AML/CFT/CPF report to the
121 16 Board, Senior Management, and Supervisory bodies?

Sub-Category 3.1 B
Q No. Question
Does your business or profession provide training to the board of directors,
122 1 managers and employees on PF-related issues?

If yes, please describe the nature of the training accordingly.

123 2

If yes, provide the total number of training over the last two years.
124 3

Does your establishment conduct regular ongoing training for staff on

125 4 AML/CFT/CPF obligations and sanctions evasion typologies annually?

Provide the total number of trainings conducted during the last calendar
126 5 year ?
 Do you use any external party for training?
127 6

Does your establishment conduct AML/CFT/CPF training immediately or

128 7 shortly after recruitment including the compliance staff?

Do you provide sufficient training to your staff to enable them to identify

129 8 UBO structure.

How is the effectiveness of internal and external training assessed ?

130 9

Does your entity ensure that the compliance officer and other relevant
employees are attending the trainings / workshops organized by MOE,
131 10
EOCN, FIU, Registrars ?

if yes, provide the total number of trainings attended during the last
132 11 calendar year ?

Sub-Category 3.2 A
Q No. Question
Do you have policies and procedures includes mitigation measures related
133 1 to cash transactions ?

Have you considered physical cash transactions while performing your

134 2 entity Risk Assessment ?

If yes, what is the risk rating assigned for physical cash transactions
135 3 considering your business model ?

Do you have scenarios in your transaction monitoring system / manual

136 4 procedures to detect the physical cash transactions ?

Have you been inspected or underwent examination from MOE or Registrar

137 5 on AML/CFT/ CPF previous five years?

138 6 If yes, please select the authority

Are there any outstanding regulatory issues related to AML/CFT/ CPF from
139 7 previous examinations ?

Were there any prior regulatory enforcement actions related to AML/CFT

140 8 and PF ?

What procedures do the entity's staff follow to ensure adequate enquiries

are made when customers attempt to make unexpectedly large cash
141 9
payments?
Sub-Category 3.2 B
Q No. Question
Have you submitted Real Estate Activity Report (REAR) reporting during the
142 1 reporting year

If yes, please provide the total number of Real Estate Activity Report (REAR)
143 2 reporting

If yes, please provide the total value of Real Estate Activity Report (REAR)
144 3 reporting (Please provide the exact value in comment box)

Sub-Category 3.3 A
Q No. Question
Do you have a transaction monitoring system?
145 1

Do you have scenarios in transaction monitoring system to identify the

below ?
a. Identify unusual cash transactions
b. Structuring transaction
146 2 c. threshold-based rules
d. customer-based rules
e. Location based rules
f. Complex transactions
g. Customer profile breach

Are higher-risk customers subject to more continuous transaction

monitoring, such as lower thresholds for alerts and more intensive
147 3
investigation?

Do you define a clear escalation framework for the review of alerts

generated through your transaction monitoring systems and/or manual
148 4
process?

Do you conduct and complete an investigation of the alerted activity?

149 5

Sub-Category 3.4 A
Q No. Question

Does your establishment maintain the most up-to-date records of the UN

150 1 Consolidated List and UAE Local Terrorist List at all times for Screening?

Did your establishment subscribe to the Sanctions List published by the

151 2 Executive Office for Control and Non-proliferation?

Sub-Category 3.4 B
 Q No. Question
Does the institution monitor Proliferation Financing red flags?
152 1

Does your business or profession consider PF-sensitive or dual-use goods as

153 2 a risk factor?

Does your business or profession have policies, procedures, and controls

154 3 related to PF-sensitive or otherwise high-risk products and services?

Has your business or profession filed any STRs with the UAE FIU related to
155 4 PF?

If the answer is yes, how many STRs related to PF have been filed during the
156 5 assessment period

Sub-Category 3.4 C
Q No. Question
Do you have alert systems include both TF and PF sanctions evasion red
157 1 flags?

Do you respond to communications (queries, requests for information, etc.)

received from EOCN via goAML message board within 48 hours of receiving
158 2
the communication?

Sub-Category 3.4 D
Q No. Question
Does your staff attend TFS training sessions held by EOCN and/or
159 1 Supervisory Authorities?

Do you verify that the TF and PF RA (Risk Assessment) are kept up to date?
160 2

Sub-Category 3.4 E
Q No. Question
Do you preform the sanction screening ?
161 1

If yes, how do you perform the sanction screening

162 2

Do you have a sanctions Compliance policy and procedure in place to cover

163 3 United Nations Security Council and UAE Local Terrorist List?

Has your establishment ever identified exposure to Sanctioned

164 4 persons/entity (by UN or UAE)?
 Does the Board and Senior Management oversee the implementation of
165 5 sanctions compliance

Does your establishment conduct screening upon any updates to the Local
Terrorist List or United Nations Consolidated List before onboarding new
166 6 customers, while at the time of KYC review and before conducting any type
of transactions (including dual used goods)?

Does your establishment freeze or suspend, without delay (within 24 hours),

all funds or other assets upon identification of confirmed or potential match
167 7
and refrain from providing any services?

Does your establishment report confirmed/potential matches on UAE Local

Terrorist List or UN Consolidated List within five business days from
168 8
implementing freezing/suspending measures?

Do you screen the customer, Beneficial Owners, beneficiaries, and

controlling persons, to screen for the applicability of targeted or other
international financial sanctions, and, particularly in higher risk situations, to
169 9
identify any potentially adverse information such as criminal history while
conducting the transaction?

Do you have a name screening system?

170 10

If yes, what is the name of the system?

171 11

Do you have a tactical/manual alternative process in place to add any

missing names in their screening list, in case they rely on an external list
172 12 provider for obtaining lists and if there is a delay in any names of recently
sanctioned persons to appear in the vendor-provided lists.

Do you conduct screening on the following:Existing customer databases. All

systems containing customer data and transactions need to be mapped to
173 13
the screening system to ensure full compliance

Do you conduct screening on the following:Potential customers before

conducting any transactions or entering a business relationship with any
174 14
Person.

Do you conduct screening on the following:Names of parties to any

175 15 transactions (e.g., buyer, seller, agent, freight forwarder, etc.)

Do you conduct screening on the following:Ultimate beneficial owners, both

176 16 natural and legal.
 Do you conduct screening on the following:Names of individuals, entities, or
177 17 groups with direct or indirect relationships with designated persons.

Do you conduct screening on the following:Directors and/or agents acting

178 18 on behalf of customers (including individuals with power of attorney).

Do you maintain records of all screening results (negative, false positive,

179 19 potential, and confirmed matches) for a period of at least five years?

Do you conduct screening on trade-based transactions that may involve

dual-use goods against the UAE Control Lists.
A. Items as mentioned on the EOCN website:
https://www.uaeiec.gov.ae/en-us/control-list- good
180 20
B. Items as per list mentioned in Cabinet Resolution No. 50 for 2020
concerning the control list annexed to Federal Law No. 13 for 2007 relating
to commodities subjected to import and export control.

Do you lift freezing measures, without delay (within 24 hours), on all funds
or other assets upon receiving notice of de-listing of designated person from
181 21 EO Notification System or upon receiving communication from EOCN on
goAML?

Does the institution have clear documented guidelines on the Sanction

182 22 Screening obligations/reporting?

Does the institution have a procedure in place to screen the customer

183 23 database immediately after a list update from the Regulator?

Does your AML Compliance procedures specify how to apply directives of

Competent Authorities for implementing UN Security Council decisions
184 24 under Chapter 7 of the UN Convention for the Prohibition and Suppression
of the FT and Proliferation?

Do you screen the customer database including, Beneficial Owners,

beneficiaries, and controlling persons, to screen for the applicability of
targeted or other international financial sanctions, and, particularly in
185 25
higher risk situations, to identify any potentially adverse information such as
criminal history?

What is the frequency of such exercise?

186 26

Do you conduct adequate internal training and awareness on TFS

obligations and sanctions evasion typologies to relevant staff and senior
187 27 management (e.g. MLROs, Front Desk Staff, Relationship Managers,
Compliance Officers, etc.)?
Sub-Category 3.5 A
Q No. Question
Does the company classify its customers according to risks?
188 1

If yes, is the risk assessment process automated or manual or combination

189 2 of both ?

If automated, please provide the name of the system used

190 3

Sub-Category 3.5 B
Q No. Question
Does the establishment conduct ongoing Enhanced Due Diligence for high-
191 1 risk customers ?

Does your establishment have checks in place to identify PEPs?

192 2

Does the Senior Management review and approve the PEP clients?
193 3

Sub-Category 3.5 C
Q No. Question
Does the institution maintain minimum KYC (Know Your Customer)
194 1 standards for customers?

Do you collect the customer’s data including details such as;

Natural persons

Full Name
Passport or identity card number
Country of issuance
Date issuance and expiry date of the identity card or passport
Nationality
Date and place of birth
195 2 Residency
Address
Phone Number

In the case of a Legal Person or arrangement

Full Name
Principal address including evidence of the permanent residential address of
a natural person
The registered address of a legal person or arrangement
Date and place of establishment or incorporation,
 Does the establishment conduct Customer Due Diligence?
196 3

Do you identify the customer, Beneficial Owner/s, beneficiaries, and

197 4 controlling persons before dealing with customer ?

Do you collect source of funds or income for physical cash transaction ?

198 5

Does your establishment verify the identification documents of clients using

199 6 reliable and independent information in all applicable cases?

Do you apply CDD measure while customers carry out occasional

transactions equal to or exceeding AED 55,000, whether the transaction is
200 7 carried out in a single transaction or in several transactions that appear to
be linked;

How frequently is the client's KYC file and documents updated ?

201 8

Do you identify third parties acting on behalf of the customer?

202 9

Do you perform additional due diligence when there is a suspicion on

203 10 previously obtained data?

How does the staff collect and record the information from the customer?
204 11

Do you gather details on the ownership structure of companies and

establishments, including those who hold significant ownership (25% or
205 12 more) and any natural person who ultimately control them, even if
ownership is hidden through other companies or people?

Do you hold the execution of business deal or transaction until the

206 13 verification of the identity is completed?

Do you engage any third party to carry out any of the AML/CFT functions of
207 14 your entity?

If yes, Do you have measures in place to ensue that the third party adheres
to the CDD measures towards Customers and record-keeping provisions of
208 15
the present laws and regulations?

Do you obtain an understanding of the intended purpose and nature of the

Business Relationship, as well as, in the case of legal persons or
209 16 arrangements, of the nature of the customer’s business and its ownership
and control structure?
 Do you collect and input data for all clients Customers and keep the same
210 17 updated ongoing basis ?

Does the institution maintain minimum KYC (Know Your Customer)

211 18 standards for customers?

Do you establish or maintain any customer or business relationship or

execute any business deal when you are unable to complete risk-based CDD
212 19
measure for the customer?

Do you ensure that documents, data or information collected under the

CDD process is kept up-to-date and relevant, by undertaking reviews of
213 20
existing records, particularly for higher risk categories of customers?

Sub-Category 3.5 D
Q No. Question
Have you rejected any prospective new customers due to the unsatisfactory
214 1 Customer Due Diligence during the assessment period?

If Yes, please list the number of rejected prospective customers due the
215 2 below reason
• Proliferation Financing Risk (PF)
If Yes, please list the number of rejected prospective customers due the
216 3 below reason
• Business Risk
If Yes, please list the number of rejected prospective customers due the
217 4 below reason
• Criminality
If Yes, please list the number of rejected prospective customers due the
218 5 below reason
• Incorrect Documents
If Yes, please list the number of rejected prospective customers due the
219 6 below reason
• PEP/FPEP (Politically Exposed Persons/Family Members)

If Yes, please list the number of rejected prospective customers due the
below reason
220 7
• STR/SAR (Suspicious Transaction Report/Suspicious Activity Report)

If Yes, please list the number of rejected prospective customers due the
below reason
221 8
• UN/UAE Sanctions

If Yes, please list the number of rejected prospective customers due the
222 9 below reason
• Other International Sanctions (e.g., OFAC, EU, HMT)
 If Yes, please list the number of rejected prospective customers due the
223 10 below reason
• Non-Cooperative

If Yes, please list the number of rejected prospective customers due the
below reason
224 11
• Any Other Reasons Not Specified Above

If your answer to above Question for this sub-category is Yes, please provide
225 12 sample case studies (1 or 2) for rejections (prospective customers) based on
unsatisfactory Customer Due Diligence; else please enter NA

Have you terminated any existing customers due to the unsatisfactory

226 13
Customer Due Diligence during the fiscal year?
If Yes, please list the number of terminations of existing customers for the
227 14 below reason
• Proliferation Financing Risk (PF)
If Yes, please list the number of terminations of existing customers for the
228 15 below reason
• Business Risk

If Yes, please list the number of terminations of existing customers for the
below reason
229 16
• Criminality

If Yes, please list the number of terminations of existing customers for the
230 17 below reason
• Incorrect Documents

If Yes, please list the number of terminations of existing customers for the
below reason
231 18
• PEP/FPEP (Politically Exposed Persons/Family Members)

If Yes, please list the number of terminations of existing customers for the
below reason
232 19
• STR/SAR (Suspicious Transaction Report/Suspicious Activity Report)

If Yes, please list the number of terminations of existing customers for the
below reason
233 20
• UN/UAE Sanctions

If Yes, please list the number of terminations of existing customers for the
below reason
234 21
• Other International Sanctions (e.g., OFAC, EU, HMT)

If Yes, please list the number of terminations of existing customers for the
below reason
235 22
• Non-Cooperative
 If Yes, please list the number of terminations of existing customers for the
below reason
236 23
• Any Other Reasons Not Specified Above

If your answer to above Question for this sub-category is Yes, please provide
237 24 sample case studies for rejections (existing customers) based on
unsatisfactory Customer Due Diligence; else please enter NA

Sub-Category 3.6 A
Q No. Question
Does your establishment have an independent audit function to test the
effectiveness and adequacy of internal policies, controls, and procedures
238 1
relating to combating Crime?

Provide the frequency of the internal audit function

239 2

Provide last independent audit report issued date

240 3

Is the Independent Audit function outsourced to a third party?

241 4

If yes, provide the name of the company

242 5

Sub-Category 3.6 B
Q No. Question
Do the Board and Senior Management receive regular AML/CFT and Internal
243 1 Audit reports?

Does the Board and Senior Management ensure that observations from the
244 2 Internal and external audits are addressed accordingly?

Has there been any specific issues highlighted in Internal Audit reports due
245 3 to the lack of controls in AML/CFT program?

Sub-Category 3.7 A
Q No. Question
Are the Owner(s)/Board of Directors/senior management of the company
246 1 involved in AML/CFT and CPF decision making?

Does your establishment maintain AML/CFT and PF Policies and

247 2 Procedures?

Are policies and procedures proportional to the risk of crime and the nature
248 3 and volume of your business?
 How frequently the policies and procedures are updated?
249 4

Are your policies and procedures approved by the Board and Senior
250 5 Management?

Has the policy been circulated to all employees and are all employees aware
251 6 about this policy?

Does your AML/CFT Manual make specific reference to proliferation

252 7 financing (PF)?

Sub-Category 3.8 A
Q No. Question
Does the establishment keep records for at least 5 years,CDD, EDD
documents including transaction records, training records, SAR/STR
253 1 (Suspicious Activity Report / Suspicious Transaction Report) records,
screening results (false positive, potential, and confirmed matches)?

Do you maintain a register of all suspicious transaction/activities reports

made to the FIU, as well as of all reports made by employees to the MLRO,
254 2 including those where a decision is made by the MLRO not to report to the
FIU?

Do you maintain a log of exited/terminated relationships and rejected

255 3 business relationships?

Sub-Category 3.9 A
Q No. Question
Do you perform the ML/TF/PF business risk assessment annually and while
256 1 introducing new products and services ?

Did your establishment carry out and document an internal risk assessment
257 2 to understand financial crime risk? And update the same periodically ?

Does the risk assessment consider the results of the National Risk
258 3 Assessment?

Does the risk assessment cover all the factors (Customer / Product & service
259 4 / Delivery channel / Geography)?
 Do you document, review and evaluate your ML/TF/PF business risk
assessment, including analysis, models, and methodologies periodically,
260 5 maintain updated documents and make them available to Ministry of
Economy upon request?

Sub-Category 3.10 A
Q No. Question
Has your entity registered with the goAML system of the Financial
261 1 Intelligence Unit?

Are all contact details in your goAML profile up to date?

262 2

Do you know how to report suspicious transactions through the goAML

263 3 system?

Sub-Category 3.10 B
Q No. Question
What is the average time taken to analyze your suspicious operations before
submitting reports to the FIU? Please specify in days (Please provide the
264 1
exact number of days in comment box)

Upon filing an STR report to FIU, do you conduct an appropriate review of

the business relationship, irrespective of any subsequent feedback provided
265 2
by the FIU, and apply appropriate risk-mitigating measures?

If customer due diligence measures cannot be completed, is a report on

266 3 suspicious activity submitted to the FIU?

Have you identified any transactions or attempted transactions related to

tax evasion or fraud related to shipping, customs or payments to facilitate
267 4
transactions for proliferation financing?

Has your establishment ever reported any suspicious transactions/activities

268 5 to the UAE Financial Intelligence Unit?

If yes, please specify the numbers

269 6

Has your establishment created and documented red-flags to provide

270 7 reasonable grounds for reporting of any suspicious transaction?

Does your establishment have a process in place to monitor and report

271 8 suspicious transactions?
 Does the compliance officer review red flags and suspicious transactions?
272 9

Does the Compliance Officer or MLRO, or Deputy MRLO file a suspicious

273 10 transaction/activities report to the FIU within acceptable timelines ?

Does your STR / SAR reporting policies and procedures include internal
274 11 reporting of SARs/STRs by employees to the Compliance Officer?

Do you scrutinize transactions undertaken throughout the course of that

relationship to ensure that the transactions being conducted are consistent
275 12 with the DNFBP’s knowledge of the customer, their business and risk profile,
including where necessary, the source of funds?

Do you have measures to ensure the confidentiality of information that is

276 13 uploaded or provided to the FIU?

Do you have a proper mechanism to provide additional information and

277 14 documentation to FIU within the timeframe provided?

If yes, please elaborate.

278 15

Has your business or profession filed any STR/SAR with the UAE FIU
279 16

If the answer is yes, how many STR/SARs have been filed during the
280 17 assessment period

Do you have a process in place for the expedited filing of urgent suspicious
281 18 transaction/activities reports in appropriate cases?

Do you document the results of review, any research or analysis performed

282 19 and recommend whether an STR or SAR should be filed?

Do you define a clear escalation framework for the suspicious transaction

283 20 indicators within your establishment?

Do you conduct and complete investigation of the potential suspicious

284 21 activity?

Are the STR/SAR reports and investigations records confidential and

maintained in safekeeping and not accessible to all staff, but only accessible
285 22
to designated staff?

Are higher-risk customers subject to more stringent monitoring, such as

implementing enhance due diligence and ongoing monitoring and more
286 23 intensive investigation in order to identify potentially unusual or suspicious
activities?
 Are all decisions to file/ not to file suspicious transaction/activities reports
documented and signed off by the MLRO or Head of Compliance or their
287 24
deputy?

Sub-Category 3.10 C
Q No. Question
Does your establishment has training program and procedures to make
employees aware of the on tipping off the clients or other parties about
288 1
monitoring or reporting of a suspicious transaction ?

Do you inform your customer, directly or indirectly, when information is

289 2 requested by the FIU?

Do you inform your customer, directly or indirectly, that a report has been
290 3 made?
 Response

DUBAI DEP OF ECONOMY&TOURISM

Limited Liability Company

INDEPENDENT ACCOUNTANTS & AUDITORS
NONE OF THE ABOVE
-Accounting and Bookkeeping
-Taxation Procedures Follow-up
-Tax Reclaim Services

RAKBANK

NO

NO

NO

NO

2 Natural Person are holding shares:

- Hakam Doudin 55%
- Bader Freihat 45%

NO

NO
NO
 7
0

NO

NO

NO

N/A

N/A

N/A

NO
0

0
 0

461

51
51
NO

N/A

NO

N/A

N/A
N/A

N/A

NO

N/A

NO

51

100

NO
NO

NO

NO

N/A

N/A

If your entity has

given POA or
authorization to any
0 third party to act on
behalf of you, then
the details of the
same should be
provided for this
question

51
 100

cash,bank transfer,cheque

NO

NO

NO

YES

6
18,000

NO

NO

NO

NO

NO

NO
N/A

N/A

N/A

NO

NO
NO
NO
NO
NO
 NO
NO

N/A

N/A

N/A

N/A

N/A

YES
50

95,000

50

3,150

0
 0

NO

NO

N/A

N/A

N/A

N/A

N/A

YES

Employee Rukhsar Bano

N/A
 12

YES

YES

YES

Senior Management

YES

YES

NO

N/A

N/A

YES

YES

TFS, Red flags, Suspicious transactions monitoring

YES

2
 NO

YES

YES

Feedbacks and Exam

YES

YES

YES

MEDIUM RISK

YES

YES

MOE

NO

N0

N/A
N/A

N/A

N/A

YES

YES

YES

YES

YES

YES

YES
 YES

YES

YES

NO

N/A

YES

YES

YES

YES

YES

b. Automoted screening system

YES

NO
 YES

YES

YES

YES

YES

YES

IDENFO

YES

YES

YES

YES

YES
 YES

YES

YES

N/A

YES

YES

YES

YES

YES

Yearly for High Risk Customers

YES
 YES

MANUAL

N/A

YES

YES

YES

YES

YES
 YES

YES

NO

YES

YES

once a year

NO

YES

a. Manual forms

YES

YES

NO

N/A

YES
YES

YES

NO

YES

NO

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A
N/A

N/A

N/A

NO

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A
 N/A

N/A

YES

YEARLY

01-Oct-24

YES

TADQEEQ

YES

YES

NO

NO

YES

YES
EVERY 6 MONTHS

YES

YES

YES

YES

YES

YES

YES

YES

YES

YES
 YES

YES

YES

YES

3 DAYS

YES

YES

NO

NO

N/A

YES

YES
 YES

YES

YES

YES

YES

YES

Any suspicious transaction will be reported within 5 days, FFR,PNMR

will be submitted to goAML within 5 days.

NO

N/A

YES

YES

YES

YES

YES

YES
YES

YES

NO

NO