A Firm must establish and maintain effective systems and controls to ensure that it complies with these sanctions

Which level of due diligence requires that we establish the source of wealth and source of funds

Suitability does not have to be considered for these clients

Who you report suspicious activity to

How long the Firm must keep its records

In the classic stages of the Money Laundering Cycle, this is the process where dirty money is integrated into the financial system

An assessment of money laundering risks and adoption of a proportionate response to such risks. The opposite of a tick box approach

This classification requires documentation of net assets and knowledge and experience

Who the MLRO reports suspicious activity to

Dave, Warren, Kristine & Lotte

To inform any person that he is being scrutinised for possible involvement in suspicious activity related to money laundering, or that any other competent authority is investigating his possible involvement in suspicious activity relating to money laundering

Charities, non-profit organisations, financial institutions in high risk jurisdictions, PEPs, complex corporate structures, SPVs

The Firm's assessment of the client's needs and objectives, and financial situation, and also, to the extent relevant, risk tolerance, knowledge, experience and understanding of the risks

Transactions with no apparent purpose;
Where a customer refuses to provide information;
An extensive use of offshore accounts;
Routing of funds through third party accounts;
Unusual transactions with no apparent profitable motive

(a) processing dealing instructions including subscriptions, redemptions, stock transfers and arranging settlements;
(b) valuing of assets and performing net asset value calculations;
(c) maintaining the share register and Unitholder registration details;
(d) performing anti money laundering requirements;
(e) undertaking transaction monitoring and reconciliation functions;
(f) performing administrative activities in relation to banking, cash management, treasury and foreign exchange;
(g) producing financial statements, other than as the Fund’s registered auditor; or
(h) communicating with participants, the Fund, the Fund Manager, and investment managers, the prime brokers, the Regulators and any other parties in relation to the administration of the Fund.

An individual with responsibility for implementation and oversight of a Firm's compliance with the rules in AML Module, who has an appropriate level of seniority and independence to act in the role

Shell companies;
Bearer share companies;
PEPs of high risk countries;
Nominee shareholders or directors

Client for whom the Firm must check that it has:

Own funds or called up capital of at least USD 1 million; and
Sufficient experience and understanding of relevant financial markets, products or transactions and associated risks

Who you are required to tell that you have submitted a suspicious activity report to Central Bank

We are not required to undertake client classification of these

A supranational organisation that produces typology reports on AML, mutual evaluations of countries' AML framework and has established 12 recommendations for best practice AML framework

* an Authorised Person;
* a Regulated Financial Institution that is subject to regulation and supervision, including AML regulation and supervision in a jurisdiction with AML regulations that are equivalent to the standards set out in the FATF Recommendations;
* a company whose Securities are listed by the DFSA, another Financial Services Regulator or a Regulated Exchange and which is subject to disclosure obligations broadly equivalent to those set out in the Markets Rules;
* a law firm, notary firm or other legal business that carries on its business in or from the DIFC; and
* an accounting firm, insolvency firm, Registered Auditor or other audit firm that carries on its business in or from the DIFC;

When calculating what must the Firm exclude the value of the primary residence of the potential customer

The name of the UAE Central Bank portal to report suspicious activity

Its Units are offered to persons only by way of a private placement;
all its Unitholders are persons who meet the criteria to be classified as Professional Clients; and
the initial subscription to be paid by a person to become a Unitholder is at least US$ 500,000