AML Software for Corporate Service Providers in UAE

This page briefly addresses the federal decree law, cabinet decisions, and sector-specific guidelines applicable to trust and company service providers in UAE and charts the varied range of AML software available for corporate service providers in UAE to automate compliance obligations. To meet their AML/CFT obligations effectively, TCSPs must rely on specialised AML software solutions that support compliance at every stage of the customer lifecycle.

Name screening software plays a vital role by automatically checking clients against global sanctions lists, politically exposed persons (PEPs) databases, and adverse media sources for any potential risk or restriction to be flagged immediately during onboarding and throughout the client relationship.

KYC Software supports the verification of client identities and establishes a clear understanding of ownership structures and the intended nature and purpose of the business relationship.

Building on this, Customer Risk Assessment evaluates the data to assign risk levels to each client. This risk rating guides the intensity of the due diligence and ongoing monitoring. In order to review client activities and profiles to detect any changes or unusual behaviour, ongoing monitoring is necessary.

Combined with transaction monitoring software, which analyses financial transactions in real time using rule-based or behavioural analytics, these tools help identify suspicious activities.

To maintain transparency, regulatory reporting software streamlines the preparation and submission of required reports to the authorities.

Together, these integrated software solutions enable TCSPs to manage their obligations efficiently, reduce risk exposure and maintain regulatory compliance.

Regulatory Framework Governing TCSPs in UAE

TCSPs in UAE are required to adhere to the AML, CFT, and CPF laws in UAE, namely:

Federal Decree-law No. (20) of 2018

Federal Decree-law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations.

Cabinet Decision No. (20) of 2019

Cabinet Decision No. (20) of 2019 Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combating of Terrorism, Terrorists Financing & Proliferation of Weapons of Mass Destruction, and Related Resolutions

Guidelines for Designated Non-Financial Businesses and Professions

Cabinet Decision No. (10) of 2019

Cabinet Decision No. (10) of 2019 Concerning the Implementing Regulation of Decree-law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations.

Cabinet Decision No. (74) of 2020

Cabinet Decision No. (74) of 2020 Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combating of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its Financing and Relevant Resolutions.

Supplemental Guidance for Trust & Company Service Providers

TCSPs are required to adhere to the AML, CFT, & CPF laws when they carry out covered activities under the AML regime. The business activities performed by TCSPs that are considered covered activities under UAE’s AML regime are as follows:

Business Activities for TCSPs Covered under UAE’s AML Regime

Business Activities for TCSPs infographic

Under the scope of activities considered covered under UAE’s AML regime includes acting as an agent in the context of a principal-agent relationship to create or establish a legal entity or arrangement, as well as serving individually or through an agency as a director, secretary, or partner (holding an equivalent position) within a legal entity. Furthermore, it also covers providing a registered office, work or residential address, correspondence, or administrative address for such entities. Additionally, it involves acting as or facilitating a trustee for a direct trust or similar arrangement, and serving as or enabling a nominee shareholder on behalf of another person.

However, it is important for TCSPs to understand that the term “covered activities” is used for the sake of convenience, and it does not intend to limit the types of business activities governed under UAE’s AML, CFT, & CPF law. The term covered activities intends to facilitate TCSPs to have a broad understanding of the types of business activities that come under the purview of AML, CFT, and CPF compliance. Further, TCSPs have to adopt a risk-based approach and take appropriate control measures while dealing with covered and non-covered activities.

Let the Law Be Your Guide

And RapidAML Your Witness

Company Service Providers and Their AML Compliance Obligations in UAE

Appointment of an AML Compliance Officer

Corporate Service Providers in UAE need to appoint an AML Compliance Officer to oversee the business’s AML compliance obligations as prescribed under UAE AML/CFT law and TFS requirements. This is a necessary prerequisite of goAML Registration for the Corporate Service Providers in UAE, failing which the CSP cannot register on the goAML portal, as the name and details of the AML compliance officer for the CSP are among the mandatory fields for goAML Registration.

goAML Registration

The registration of Corporate Service Providers operating in UAE is a compliance requirement that enables TCSPs to file regulatory reports as and when they encounter suspicious activity or a transaction or engage in designated transactions. The process of goAML Registration on UAE FIU’s goAML portal is approved by the relevant and applicable supervisory authorities in UAE.

ML/FT and PF Risk Assessment

Corporate Service Providers operating in UAE must:

Refer to our YouTube Video:

AML/CFT Policy & Procedures Drafting

Corporate Service Providers operating in UAE must draft, formulate, catalogue, and periodically update AML, CFT, & CPF Policies, Procedures, and Controls to mitigate identified ML, FT, & PF risks while considering distinctive and risk-based compliance measures for "Covered" and "Non-Covered" activities. For more insights into AML/CFT policies and procedures, refer to:

Our eBook :

Videos :

Staff Training and Awareness 

TCSPs must ensure that their staff, be it customer-facing or the compliance team, are adequately trained to identify and report ML, FT, and PF red flags to UAE FIU through the goAML portal.
For more insights into Staff Training and Awareness, refer to : AML/CFT Training and Awareness Programs for Effective KYC Implementation 

Regulatory Reporting

TCSPs in UAE need to file the following reports through the goAML portal:

For detailed insights into suspicious transactions, check out our blog: An Ultimate Guide To Investigating Suspicious Transactions

Record-Keeping

TCSPs must ensure adequate record-keeping for the prescribed duration based on the supervisory authority such as ADGM, DIFC, VARA, SCA, etc. For more insights into record-keeping under UAE’s AML/CFT law, refer to :

Governance

The three lines of defence serve as a governance structure for TCSPs in UAE.
For more insights into governance through Three Lines of Defence, refer to:

Independent AML Audit

TCSPs must ensure that they conduct timely, independent AML audits to assess the efficacy of their AML/CFT control measures, followed by the implementation of remedial measures if required.

The Law Draws a Line

Compliance Must Walk It

Implementing a Risk-Based Approach (RBA) to Customer Onboarding for TCSPs in UAE

TCSPs operating in UAE must have distinct methodologies in place to deal with customers posing varying levels of ML, FT, or PF risks to the TCSPs. This categorisation of ML, FT, and PF risk must be derived while considering whether the services sought by the prospective or existing customer come under the category of covered or non-covered activities under AML regulation. This helps TCSPs adhere to the sector-specific guidelines for the TCSPs, UAE AML/CFT laws, and the FATF recommendations concerning conducting customer due diligence (CDD) with a risk-based approach (RBA).

As mentioned under UAE AML/CFT laws and guidelines, TCSPs must use technology to streamline their AML/CFT obligations. Delegating repetitive manual tasks for automation takes the compliance load off the backs of the AML Compliance Officer and facilitates the staff and senior management of TCSPs’ focus on business goals while streamlining AML/CFT compliance with unified AML software.

AML Software: TCSPs Key to Robust AML Compliance in UAE

Great Things Rise Above

Unified and Floating in the Cloud

AML Software for Corporate Service Providers

PEP, Adverse Media, and Sanctions Screening Software

KYC Software

Customer Risk Assessment Software

Transaction Monitoring Software

Enterprise-Wide Risk Assessment Software

Regulatory Reporting Software

Case Management Software

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