April 18, 2018

Dubai FSA launched the second phase of its consultation process that proposes changes (via CP120) to the Anti Money Laundering, Counter-terrorist Financing, and Sanctions (AML) Module of its Rulebook. The proposed changes are intended to ensure that the AML regime is compliant with the 2012 Financial Action Task Force (FATF) recommendations. Comments are due by May 20, 2018, using the table provided in Appendix 3.

The consultation paper contains background to the proposal, specific noteworthy issues, and an explanation of the proposed changes to the AML Module. Appendix 1 to the consultation paper includes draft amendments to the AML Module while Appendix 2 contains draft amendments to the Conduct of Business (COB) Module. The areas in which Dubai FSA is proposing amendments include customer due diligence, record keeping, new technologies, wire transfers, reliance on third parties, internal controls and foreign branches and subsidiaries, higher risk countries, and transparency and beneficial ownership of legal arrangements.

FATF is the global standard-setter in the fight against money laundering and combating the financing of terrorism and terrorist acts. The recommendations developed by FATF are revised periodically to ensure that countries respond to the current money laundering and terrorist financing threats as well as other threats to the financial system. FATF monitors, by means of a mutual evaluation, the progress of its members in implementing these recommendations. The next UAE FATF mutual evaluation will take place in the second half of 2019. Dubai FSA, as a stakeholder, is expected to contribute to this mutual evaluation. Dubai FSA has reviewed its AML regime (via a self-assessment process) to assess whether it meets the recommendations set by FATF and identified areas that required change. Dubai FSA consulted on these identified change requirements in March 2018 via CP118, which constituted the first phase of the consultation process.


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Comment Due Date: May 20, 2018

Keywords: Middle East and Africa, United Arab Emirates, Banking, AML Regime, Rulebook, FATF, AML/CFT, Dubai FSA