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Some AML Resources from the UAE

From the resource page below, we have the following from the Central Bank of the UAE: Law: Federal Decree-Law No (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations Cabinet Decision: Cabinet Decision No (10) of 2019 concerning the Implementing Regulation of […]

May 2020: NCA guidance on making better SARs

There’s much more in this document, but I thought I’d highlight Section 6 (“good practice tips): Always  identify as clearly as possible the suspected benefit from criminal conduct (the ‘criminal property’) including, where possible, the amount of benefit  identify the reason(s) for suspecting that property is criminal property […]

OFAC’s Framework: Root Causes of Compliance Breakdowns & Deficiencies, #6-10

VI. Sanctions Screening Software or Filter Faults Many organizations conduct screening of their customers, supply chain, intermediaries, counter- parties, commercial and financial documents, and transactions in order to identify OFAC- prohibited locations, parties, or dealings. At times, organizations have failed to update their sanctions screening software to incorporate updates to […]

OFAC’s Framework: Training

TRAINING An effective training program is an integral component of a successful SCP. The training program should be provided to all appropriate employees and personnel on a periodic basis (and at a minimum, annually) and generally should accomplish the following: (i) provide job-specific knowledge based on need; (ii) communicate the […]

OFAC’s Framework: Testing and Auditing

TESTING AND AUDITING Audits assess the effectiveness of current processes and check for inconsistencies between these and day-to-day operations. A comprehensive and objective testing or audit function within an SCP ensures that an organization identifies program weaknesses and deficiencies, and it is the organization’s responsibility to enhance its program, including […]

OFAC’s Framework: Internal Controls

INTERNAL CONTROLS An effective SCP should include internal controls, including policies and procedures, in order to identify, interdict, escalate, report (as appropriate), and keep records pertaining to activity that may be prohibited by the regulations and laws administered by OFAC. The purpose of internal controls is to outline clear expectations, […]

OFAC’s Framework: Risk Assessment

RISK ASSESSMENT Risks in sanctions compliance are potential threats or vulnerabilities that, if ignored or not properly handled, can lead to violations of OFAC’s regulations and negatively affect an organization’s reputation and business. OFAC recommends that organizations take a risk-based approach when designing or updating an SCP. One of the […]