What ongoing monitoring must a UAE DNFBP perform on its customer relationships?
Ongoing monitoring is a continuing obligation for every UAE Designated Non-Financial Business or Profession (DNFBP), not a one-time check at onboarding. The DNFBP must keep each business relationship under review so that its understanding of the customer, and the risk it poses, stays accurate over time.
In practice this means scrutinising transactions throughout the relationship to ensure they are consistent with the DNFBP’s knowledge of the customer, their business and risk profile, and the expected source of funds. It means keeping customer due diligence information, including identity and beneficial-owner details, current and updating it when circumstances change or at intervals set by the customer’s risk rating. Higher-risk customers, including politically exposed persons, warrant more frequent and intensive monitoring, while genuinely low-risk relationships may be monitored less often under a documented simplified approach. Where monitoring reveals unusual or unexplained activity, the DNFBP must investigate and, if suspicion arises, file a Suspicious Transaction Report.
All monitoring activity and the records that support it must be retained for at least five years and made available to the supervisory authority on request.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(b) — customer due diligence and continuous monitoring procedures.
· Cabinet Resolution No. 134 of 2025, Article 25 — retention of customer due diligence and monitoring records for at least five years.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.