When must a DNFBP carry out customer due diligence in the UAE?
A DNFBP must carry out customer due diligence at defined trigger points rather than only at onboarding. Due diligence is required when a business relationship begins, whenever there is a suspicion of a crime regardless of any threshold, and whenever there are doubts about the accuracy or adequacy of customer identification data obtained earlier.
For dealers in precious metals and stones the threshold-based trigger is a cash transaction of AED 55,000 or more, whether a single dealing or several linked dealings. Due diligence means identifying and verifying the customer, identifying and verifying the beneficial owner, understanding the purpose and intended nature of the relationship, and conducting ongoing monitoring throughout.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 7 - lists the situations in which customer due diligence must be applied.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3(3) - the AED 55,000 threshold for dealers in precious metals and stones.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.