When must a DNFBP apply enhanced due diligence in the UAE?
A DNFBP must apply enhanced due diligence whenever the money laundering or terrorist financing risk is higher than normal. Typical high-risk situations include dealings with politically exposed persons, customers or transactions connected to high-risk jurisdictions, complex or opaque ownership structures, unusually large or unusual transactions, and any relationship where the risk-based assessment points to elevated exposure.
Enhanced measures go beyond standard due diligence. They include obtaining and verifying additional information on the customer, occupation, and beneficial owner, establishing the source of funds and source of wealth, obtaining senior management approval to start or continue the relationship, and increasing the frequency and depth of ongoing monitoring. The measures should be documented so the DNFBP can show its supervisor how risk was managed.
Legal Reference (UAE):
ยท Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 5 - requires enhanced due diligence measures for higher-risk customers and lists examples such as source of funds and closer monitoring.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.