The Significance of Ongoing Monitoring in AML Compliance

The Designated Non-Financial Businesses and Professions (DNFBPs) and Virtual Asset Service Providers (VASPs) need to monitor ongoing business relationships with their existing customers. This ongoing monitoring entails scrutiny of customers’ activities, such as transactions executed throughout the business relationship, to ensure that they remain consistent with the customers’ profiles. The factors signifying the importance of ongoing monitoring are discussed as follows:

Compliance with KYC regulations

The practice of conducting ongoing monitoring helps businesses such as DNFBPs and VASPs comply with prevailing KYC norms prescribed under the federal AML/CFT laws, cabinet decisions and sectoral guidelines.

Counter ML/FT/PF

The practice of conducting ongoing monitoring helps regulated entities identify and detect the red flags of customer conduct and take necessary mitigation measures to counter the ML/FT and PF risk.

Risk-Based approach in customer onboarding

The practice of conducting ongoing monitoring helps businesses to implement a risk-based approach (RBA), which is the backbone of AML/CFT laws in the UAE, derived from the recommendations of the Financial Action Task Force (FATF). RBA requires the implementation of ML/FT and PF risk mitigation measures in proportion to the ML/FT and PF risk the businesses face at the enterprise level.

Detecting suspicious activities

The practice of ongoing monitoring, when implemented by trying and testing in accordance with the RBA helps businesses such as DNFBPs and VASPs detect suspicious activity that could relate to ML/FT or PF related crimes.

Enhanced Due Diligence

The practice of customer due diligence and ongoing monitoring helps regulated businesses identify customers on whom enhanced due diligence (EDD) needs to be carried out, usually due to a shift in their risk rating detected during ongoing monitoring. Such EDD measures may include seeking the customer’s source of funds and wealth.

Regulatory Reporting

The practice of ongoing monitoring helps comply with regulatory reporting requirements for suspicious activities on the goAML portal.

Thus, ongoing monitoring of business relationships is a significant component of AML compliance in UAE, helping businesses such as DNFBPs and VASPs to combat the risk of ML/FT and PF effectively.