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Compliance and AML

The United Arab Emirates is a member of the Gulf Cooperation Council, which, in turn, is a member of the Financial Action Task Force (FATF) on Money Laundering and Terrorism Financing. The UAE demonstrates its commitment to combating Money Laundering and Terrorism Financing through the Anti-Money Laundering and Combatting the Financing of Terrorism Supervision Department (AMLD). Through supervisory oversight, the AMLD ensures all Banks, Exchange Houses (EHs), Finance Companies, Stored Value Facilities (SVFs), Retail Payment Services/Card Schemes (RPSCS), Payment Token Service Providers (PTSPs), Registered Hawala Providers (RHPs), Insurance Companies, and related professionals (collectively LFIs/RHPs/ICRPs) comply with the UAE’s AML/CFT/CPF legal framework, including Federal Decree-Law No. (6) of 2025 and Federal Decree Law No. (10) of 2025.

Asma Ali Al Messabi Advocates and Legal Consultants (“We,” “Us,” or “the Company”) establish Compliance and AML policies to ensure adherence to local, international regulations, and FATF recommendations on AML and CTF.

Policies and Principles

The Company’s AML Team owns and is responsible for these policies: Anti-Money Laundering/Counter-Terrorist Financing, Sanctions Compliance, Targeted Financial Sanctions (TFS), Correspondent Banking Relationships, FATCA Compliance, CRS (Common Reporting Standard), and Anti-Money Laundering Policy.

The Company’s AML Policy defines the minimum standards for compliance. The Money Laundering Reporting Officer (MLRO) is accountable for overseeing compliance with relevant regulations, rules, and best practices.

  • Implement and maintain risk-based customer due diligence, identification, verification, and Know Your Customer (KYC) procedures. Apply enhanced diligence to higher-risk clients, including Politically Exposed Persons and Correspondent Banking Relationships.
  • Maintain risk-based systems and procedures to monitor ongoing customer account activity.
  • Report suspicious transactions internally and to regulatory authorities, including the Financial Intelligence Department at the Central Bank of the UAE.
  • Maintain appropriate records for the minimum prescribed periods as required by local regulations.
  • Provide AML training and awareness for all relevant employees.
  • Ensure appropriate management information and reporting on AML matters to the Senior Management of the Bank.

Compliance and AML Policy Statement

Sanctions Compliance Policy

The Company is committed to ensuring compliance with all applicable economic sanctions laws in every jurisdiction in which it operates or trades.

The Company screens customers and transactions in the following steps:

(1) Retrieve up-to-date global and local sanctions lists (UNSC, EU, UK-HMT, US-OFAC, and relevant UAE lists).

(2) Screen all customer and transaction data against these lists.

(3) Document any potential matches and escalate for review by the compliance team.

(4) Confirm action and file outcomes for audit and compliance records.

Prohibited business activity includes onboarding or continuing customer relationships, providing products or services, or facilitating transactions that the Company believes may violate applicable sanctions or this policy.

The Company also prohibits business with individuals or entities named in a sanctions list, as well as any activity involving countries or territories under comprehensive sanctions. These countries include Cuba, Iran, North Korea, Syria, Russia, and the Crimean Region of Ukraine.

It is the Company’s policy not to deal with any person or entity that may result in a violation of any sanctions regulations.

All employees receive ongoing training on the Sanctions Compliance Policy.

Targeted Financial Sanctions (TFS)

To ensure the Company complies with applicable Targeted Financial Sanctions, it must screen existing, new, and potential clients against sanctions lists. The Company should follow guidelines on Targeted Financial Sanctions (TFS) issued by the UAE, the UN, and the FATF.

The Company will take all necessary steps to prevent funds or other assets from being made available, directly or indirectly, for the benefit of listed individuals, groups, or entities.