DPMS - AML PPT 3.7

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Dealers in Precious Metals & Stones,

Precious Safeguards: Navigating the


UAE's Anti-Money Laundering
Landscape
Why is AML training critical for your employees

Awareness of money laundering threats and mitigating measures is essential for any
company to safeguard the business from being exploited by financial criminals.

Awareness of threats allows people to use the right action plans to combat the same.

AML Compliance Officer cannot single-handedly identify and fight the money laundering
threats. He needs support from every single employee of the company.
And here comes the need to train the employees. If you train your employees on money
laundering threats, they can take steps to manage or reduce ML/FT risks.

AML training is crucial to any organization’s overall AM/CFT framework.


Importance of AML training

Organized criminals launder dirty money into the financial system, using legit business
organizations as their means. Without well-trained employees, business organizations
could not detect such crimes being executed through them. An AML-trained employee
would act as a line of defense and contribute towards making the company a hostile
setting for laundering money.

Some companies say they know all their clients and do not expect any threat from them.
Some say that they are too small to conduct training for employees. Whatever the case
is, AML training is vital to keep money laundering risks at bay.

Financial criminals do not attack a business based on size or business-client relationship.


They keep looking for new tactics to launder small or significant amounts of money
through any method, with the only intention of not getting caught.

So, every firm to whom AML regulations are applicable must conduct AML training for its
employees, making employees capable enough to identify suspicious activities or
transactions and report the same promptly.
Importance of AML training

It is mandatory for Designated Non-Financial Businesses and Professions (DNFBP’s), to


comply with AML regulations and their requirements. As one of the requirements is to
conduct ongoing AML training for the staff, all the obligated entities shall comply with the
same to avoid non-compliance penalties and ensure a better AML framework to fight
money laundering (ML) and financing of terrorism (FT).

With all these requirements, employees need to know their role in fighting ML/FT and how
to do their duties. They must know the trending anti-money laundering typologies to
identify the threats in routine business operations quickly.

To safeguard the business and its reputation, Companies need skillful and knowledgeable
employees to implement a robust AML framework to safeguard the business from being
exploited by money launderers.

AML training brings a consistent understanding, across all levels, of the importance of
AML compliance and their role in identifying ML/FT threats to save the company and its
reputation. All the employees, including the senior management, stay more aligned with
AML-related organizational objectives, resulting in the more successful adoption of the
AML/CFT compliance program.
Participants in AML training

All the relevant employees handling customers, transactions, and delivery channels must
receive adequate AML training, whether a full-time employee or a part-time or
contractual one. If they, in any way, are involved in activities related to customer-
servicing or business partner interactions, they must receive the necessary training
around AML and CFT.

As the AML Compliance Officer is the person running the show, he must be well-trained,
well-qualified, and well-aware of the basic AML concepts, regulatory obligations, roles,
and responsibilities to handle the AML/CFT framework of the company, etc.

AML Training requirement is not just limited to front-line employees; AML training is also
critical for senior management. Senior management is responsible for implementing an
effective and comprehensive AML compliance program. They need to understand the
basic concepts and regulatory requirements to efficiently manage the AML framework
across the organization. Thus, senior management shall also be included in training
programs and lead by example.
AML Fines & Penalties in UAE

AML compliance is mandatory for financial institutions, Designated Non-Financial


Businesses and Professions (DNFBP), and other regulated entities. The UAE Ministry of
Economy announced different Money Laundering Fines and Penalties in UAE. The
Ministry has listed 26 categories of fines for violating the money laundering and terrorism
financing laws.

The UAE government monitors the AML compliance and has set up a specialised unit to
investigate the control of DNFBPs, dealers in precious metals and stones, auditors, real
estate agents and brokers, etc., as such businesses and professionals are prone to
money laundering and corruption.

Let’s know the different fines and penalties applicable in the UAE for violating AML rules
and regulations.
Money Laundering Fine of Dirhams 1 million or more

When organizations fail to take appropriate


actions for customers included in the
international or local sanction lists – they
must follow the due diligence process
before starting a business relationship.

If there is a dealing with unauthorized


banks, AED 1 million or more fine is also
applicable. The penalty is also applicable if
bank accounts are opened or maintained
using fake names, not the actual holders’
names.
Money Laundering Fines and Penalties of Dirhams 200,000 and above

If the Enhanced Due Diligence process is not followed to identify the high-risk
customers.
If the FIU- Financial Information Unit is not informed of the STR- Suspicious
Transaction Report in cases where the institutions cannot follow the customer
verification process- due diligence process before creating or maintaining a business
relationship or carrying out a transaction for the benefit of the client or in his name.
If the FIU has asked for additional information for the reported suspicious transactions
and organizations fail to comply, then a fine is also levied in such cases.
Due to suspicions about the nature of the business relations- its process or intentions
are disclosed directly or indirectly to the customer or a third party. In that case, such
actions attract a penalty of AED 200,000 or more.
If the measures identified by the National Committee for Combating Money
Laundering regarding customers from high-risk countries are not implemented, the
fines are levied.
Money Laundering Fines and Penalties of Dirhams 100,000 and above

If the requisite measures are not adopted for identifying risk and evaluating the same
when the services are provided or undertaken with new professional activities.
If the requisite due diligence measures are not taken for clients before establishing or
continuing a business relationship or making a transaction that benefits the customer.
If the customer identity and that of the UBO or their deputy is not verified before or
while establishing a business relationship or before with a client with whom there’s no
previous business relationship.
If there’s a delay of information about the STR to the FIU in events where there’s a
suspicion that the customer is related to crime wholly or partly- if there’s reasonable
ground to suspect that the client money is involved in establishing the business
relationship has been obtained from criminal activities.
If the due diligence measures are not followed for PEPs-Politically exposed Persons
before establishing or maintaining a business relationship.
If proper records are not maintained on the financial transactions with the customers.
Conclusion: Precious Metals, Precious
Safeguards

In conclusion, it is crucial for dealers in precious metals or


stones in UAE to comply with Anti Money Laundering rules
to prevent illegal activities.

Our AML solutions assist in putting in place stringent


monitoring procedures to ensure complete adherence to
legal requirements.
Thanks
!
Do you have any
questions? @nrdoshi.com
+971
www.nrdoshi.ae

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