What CDD measures must a DPMS apply when a transaction reaches AED 55,000?
Once a single or linked cash transaction reaches AED 55,000, a DPMS must apply the full Customer Due Diligence package set out in the Executive Regulation. This includes verifying the customer’s identity from independent and reliable sources such as Emirates ID for residents, valid passport for non-residents, and valid trade licence and ownership chart for corporate customers. The DPMS must identify and verify any beneficial owner with 25% or more ownership or effective control under Cabinet Resolution 109/2023.
The DPMS must understand the purpose and intended nature of the relationship, capture details of the source of funds and, where appropriate, the source of wealth, and screen the customer and beneficial owner against the UAE Local Terrorist List and UN Consolidated Sanctions list at onboarding and continuously thereafter. For corporate customers, the DPMS must collect the trade licence, articles of association, share register, ownership chart, authorised signatory documents, and proof of identity for all directors and beneficial owners.
Where risk is elevated, high-risk jurisdictions, PEPs, complex ownership structures, large unexplained cash payments, customers reluctant to provide information, Enhanced Due Diligence must be applied, including detailed source of funds and source of wealth verification, senior management approval to onboard or continue the relationship, and ongoing enhanced monitoring of transactions. Simplified CDD is permitted only where the entity-wide risk assessment establishes a clear lower-risk profile and the customer fits the simplified criteria. All CDD records and supporting documents must be retained on the goAML portal and in internal systems for at least five years from the relationship’s end.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Articles 7 to 10 — CDD measures
- Cabinet Resolution No. 109 of 2023 on Real Beneficiary Procedures, Article 5 — beneficial ownership identification
For more details, consult the full text of Cabinet Resolution 134/2025