AML Compliance Calendar
AML Compliance Calendar
The AML regulations in the UAE impose many compliance obligations on Designated Non-Financial Businesses and Professions (DNFBPs). DNFBPs may face issues in managing these compliances on a timely basis. Now, with AML UAE’s AML Compliance Calendar, manage your overall AML compliance journey with proper planning and do not stand a chance to miss any deadline.
Some requirements are ongoing or event-specific, requiring an immediate attention, while some are annual and have a timeline prescribed to fulfil the compliance obligation. Here is the table depicting the primary AML obligations of DNFBPs, timelines and how the AML Compliance Calendar can help you up your AML Compliance game and avoid non-compliance penalties:
Mapping of AML Obligations with AML Compliance Calendar
|
AML Obligation |
Timelines |
AML Compliance Calendar’s tips |
|
1. Customer Due Diligence |
Regularly (Before customer onboarding or executing a transaction) |
Do not neglect CDD. Get a daily notification at the end of the day, check whether the CDD process is completed for the customers who approached you TODAY. |
|
2. Transaction Monitoring |
Regular |
Identify any suspicious pattern. Daily trigger at the beginning of the day reminding you to follow the ongoing transaction monitoring process before executing a transaction with an existing customer. |
|
3. Compliance Officer’s AML Report |
Periodic (Monthly/Quarterly) |
Let senior management be aware of AML happenings. Set reminders for Compliance Officer to ensure timely preparation and submission of periodic AML reports to the senior management. |
|
4. Reviewing CDD profiles |
At predetermined frequency (e.g., High-risk customers: Half yearly Medium-risk customers: Annually Low-risk customers: Annually) |
Keep your CDD files updated. Don’t let your customer due diligence information be irrelevant. Ensure timely review of customer profiles basis the ML/FT risk category assigned. |
|
5. AML Training |
Regularly (Monthly) |
Promote strong AML Compliance Culture. As AML UAE schedule the training, get it automatically synced to your calendar. |
|
6. Independent AML Audit |
Basis AML risk and business activities (Yearly) |
Get your AML framework validated. Annual reminder to appoint a proficient independent person to check your AML program’s efficiency and quality. |
|
7. Annual AML Return |
Annually DIFC units: August to July in September ADGM units: January to December in April |
Let’s be on time! AML UAE’s specific reminder for units operating in DIFC or ADGM to ensure timely filing of Annual AML Return. |
|
8. Review and update AML Business Risk Assessment |
Annually or upon a change in risk parameters |
Do not stay outdated. Get an annual notification highlighting your to-do to review your last AML Business Risk Assessment and update it in line with revised ML/FT risk exposure. |
|
9. Updating AML framework |
Annually or upon a change in regulatory requirements |
Follow the Law! Get timely triggers from AML UAE’s dynamic AML calendar as and when there are any regulatory amendments around AML – whether by UAE authorities, FATF, or United Nations. |
|
10. Any additional requirements from Supervisory Authority (like Surveys) |
As and when issued |
Forget the Fear Of Missing Out! As the supervisory authority issues the survey or program for collecting annual AML risk assessment data, getting near real-time updates through AML Compliance Calendar to not miss any deadline. |
Significance of following AML Compliance Calendar
1. Perform adequate Customer Due Diligence (CDD) process for your customers, suppliers and third parties with whom you transact. These CDD measures consist of identifying the customers (through the Know Your Customer (KYC) form), screening and risk profiling the customer. The CDD measures are to be applied before establishing a business relationship with the customer/supplier or executing a transaction in case of an occasional customer.
2. Risk mitigation measures are incomplete unless the customer’s transactions are monitored regularly. The AML laws require the DNFBPs to implement an ongoing transaction monitoring program to identify any unusual activity or pattern of transaction contradictory to the customer’s expected profile.
3. To ensure that the senior management of the DNFBP is aligned with the ongoing activities around the AML framework, the laws mandate the Compliance Officers to furnish a periodic AML Report to the senior management. The Compliance Officer’s AML Report must include the following:
- Statistics around customer’s risk profile and CDD measures applied
- Information about reporting done with the Financial Intelligence Unit
- Any additional resources required in the company for managing the AML compliance framework
- Any new ML/FT red flags observed
- Suggestions or comments from the AML auditor, etc.
4. DNFBPs must always keep the information about the customer updated. Thus, the Customer Due Diligence monitoring program be deployed to ensure the relevance and validity of the CDD profiles. DNFBPs must frequently review the customer’s due diligence, including the risk profile for customers classified as “high-risk”. While for low and medium-risk customers, a lesser frequent monitoring process can be implemented.
5. AML Training is necessary for every DNFBP – for the Compliance Officer, staff, and senior management to ensure effective implementation of the AML framework across the company. Training programs must be developed considering the significance of AML awareness amongst all employees and role-specific learning needs.
6. AML Law mandates the implementation of an independent AML Audit function to check the efficiency and quality of the AML framework. The frequency and extent of AML audits depend on the nature & size of DNFBP’s business operations, AML business risk assessment, etc.
7. Financial Services Regulatory Authority (FSRA) and Dubai Financial Services Authority (DFSA) require the DNFBPs operating in ADGM and DIFC to file an annual AML return detailing the company’s AML compliance status and activities undertaken during 12 months.
8. Assessing the AML business risk is essential to understand the DNFBP’s vulnerability to ML/FT risk and designing the AML policies, procedures, and controls accordingly. The risk parameters may keep on changing with the company’s evolving business. Accordingly, DNFBPs must review and update AML Business Risk Assessment at least once a year or upon a material change in the significant risk factor.
9. DNFBPs must maintain their AML/CFT Policies, Procedures, and Controls updated with the regulatory amendments, company business activities change, and ML/FT business risk assessment. AML Compliance Officer should update its AML Compliance framework at least once a year or upon significant changes in the AML regulations, business operations or ML/FT risk parameters.
10. Financial Intelligence Unit requires the DNFBPs to file a relevant report on the goAML portal in case of identification of any suspicious transaction or suspicious activity or where a confirmed or partial match is found with the Sanctions List or for specified transactions such as REAR or DPMSR. DNFBPs must comply with the following goAML reporting requirements:
Apart from the above routine AML compliance tasks, the DNFBPs must ensure that it is registered with the goAML Portal and has its details up-to-date on the portal, including the appointment of the duly competent AML Compliance Officer.
Sync the AML Compliance Calendar with your Outlook or Gmail account and get timely notifications to achieve your AML compliance obligations.
Stay updated, stay compliant and avoid any non-compliance penalties.