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

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

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

The risk based assessment that must be undertaken by a Firm on a customer and the proposed business relationship, transaction or product. The outcome of this process is to produce a risk rating for a customer, which determines the level of Customer Due Diligence which will apply to that Customer.

Client classification for Clients receiving the services of Arranging and Advising for the purposes of corporate structuring and financing

Who the MLRO reports suspicious activity to

Hassan; Marwan; Mishal; Omar; Shinas and 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

This classification requires documentation of net assets and knowledge and experience

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

Financial service: managing on a discretionary basis assets belonging to another person

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

Obtain and verify ID after business is initiated;
Reduce frequency of ID updates;
Reduce monitoring;
Not obtain information on intended business

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

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

Financial service: Assisting the client with arranging, safeguarding and administering client investments; and
Not being legally accountable to clients for safeguarding and administering client investments

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

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

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