Step by Step Guide to Conduct Customer Due Diligence for AML

Step by Step Guide to Conduct Customer Due Diligence for AML Compliance in the UAE

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Step by Step Guide to Conduct Customer Due Diligence for AML Compliance in the UAE

In the United Arab Emirates (UAE), tackling money laundering and terrorist financing is a top priority for financial institutions and businesses. Customer due diligence (CDD) is a critical component in meeting anti-money laundering (AML) obligations. In this guide, we will highlight the ten essential steps to carry out effective CDD and adhere to the regulations of AML in UAE.

1) Comprehend the Regulatory Framework

Acquaint yourself with the AML regulations and guidelines provided by the UAE’s regulatory bodies, including the Central Bank, the Financial Intelligence Unit (FIU), and the Securities and Commodities Authority (SCA). Stay updated with any changes or new requirements to maintain compliance. Moreover, it is vital to comprehend the global standards established by organizations such as the Financial Action Task Force (FATF) and integrate them into your AML procedures.

2) Establish Risk-Based Protocols for Customer Due Diligence

Implement a risk-based approach for CDD, involving the evaluation and classification of customers according to their risk profiles. This allows for efficient resource allocation and prioritization of higher-risk clients for advanced due diligence measures. Take into account factors like customer type, geographical location, transaction magnitude, and intricacy of the business relationship to determine the suitable level of due diligence.

3) Gather Adequate Customer Data

Collect precise and comprehensive customer data, such as identification documents, proof of address, business or occupation nature, and details on beneficial ownership. Confirm the authenticity of these documents to reduce the potential for identity theft or fraudulent actions. Establish procedures to acquire and refresh this information periodically, ensuring its accuracy.

4) Conduct Customer Screening for Proper for Due Diligence

Conduct thorough screening processes using global sanctions lists, politically exposed persons (PEPs) databases, and other relevant watchlists. This aids in identifying individuals or entities linked to money laundering, terrorism, or financial offenses. Furthermore, contemplate incorporating continuous monitoring tools that offer real-time notifications for any alterations in a customer’s risk profile.

5) Evaluate the Source of Funds and Assets

Investigate the origin of the customer’s funds and confirm their legitimacy. Examine transaction history, business activities, and financial statements to detect any discrepancies or dubious transactions that could suggest money laundering or unlawful activities. Likewise, evaluate the customer’s total wealth and financial status to ascertain if it corresponds with their stated income source.

6) Establish the Intent of the Business Relationship

Comprehend the objective and intended nature of the business relationship with the customer. Determine whether the customer’s activities are consistent with their declared objectives, and identify possible warning signs, such as atypical transaction patterns or a lack of reasonable explanation for their business operations. Evaluate the risk level associated with the customer’s industry or sector.

7) Execute Advanced Due Diligence Procedures

For customers considered high-risk, perform enhanced due diligence. This might entail collecting extra information, executing site visits, or employing external specialized agencies to evaluate the customer’s background, reputation, and the validity of their business activities. Record the results of the due diligence procedure to exhibit adherence to regulatory mandates.

8) Maintain Ongoing Monitoring

Set up an effective system for continuous monitoring of customer accounts and transactions. This encompasses revisiting customer information periodically, scrutinizing transaction patterns, and swiftly examining any suspicious activities. Consistently update customer records and carry out periodic Customer Due Diligence (CDD) reviews. Incorporate advanced analytics and monitoring instruments to identify unusual or potentially illegal activities. Also make use of technology to automate the AML compliance of your business.

9) Educate Employees and Increase Awareness

Allocate resources to comprehensive AML training programs for employees, ensuring they grasp their responsibilities and the processes entailed in CDD. Frequently inform staff about emerging risks, typologies, and regulatory modifications. Cultivate a culture of compliance and promote reporting of suspicious activities. Create a whistleblower policy to safeguard employees who disclose potential AML infringements.

10) Maintain Adequate Recordkeeping and Reporting

Maintain accurate and up-to-date records of all CDD activities, comprising customer information, screening outcomes, risk evaluations, and transaction logs. Retain these records for the required duration, as dictated by the UAE’s AML regulations. Establish strong reporting mechanisms to swiftly submit suspicious activity reports (SARs) on GoAML system to the Financial Intelligence Unit (FIU) in accordance with the law.


In conclusion, conducting comprehensive customer due diligence is crucial for preventing money laundering and terrorist financing activities in the UAE. By adhering to this step-by-step guide, financial institutions and businesses can create robust AML compliance frameworks that not only fulfill regulatory requirements but also contribute to preserving the integrity of the financial system and safeguarding their reputation and stakeholders’ interests. Keep in mind, compliance is a continuous process, and staying current with evolving regulations and emerging risks is vital for effective AML practices. Implementing solid CDD measures not only diminishes the risk of financial crimes but also fosters trust and stability in the UAE’s financial landscape.



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