Compliance with AML Laws: Guide to Filing a Fund Freeze Report (FFR) | AML UAE

Introduction

This tutorial provides a comprehensive guide on how to file a Fund Freeze Report (FFR) in compliance with Anti-Money Laundering (AML) laws in the UAE. It outlines the necessary steps for Designated Non-Financial Businesses and Professions (DNFBPs) when they identify clients matching the UAE’s local terrorist list or the UNSC Consolidated list. Understanding these steps is crucial for ensuring compliance and avoiding penalties.

Step 1: Understand the Regulatory Framework

• Familiarize yourself with Cabinet Decision (74) of 2020 regarding Terrorism Lists Regulation.
• Recognize the importance of compliance with UN Security Council Resolutions on combating terrorism and its financing.

Step 2: Conduct Customer Screening

• Implement a robust customer screening process before processing any transactions or when there are changes in customer information.
• Screen:
  • Existing customer databases.
  • Potential customers.
  • Other parties involved in the transaction, such as agents, beneficial owners, and directors.
• Check against:
  • UNSC Consolidated List.
  • UAE Local Terrorist List.
  • Relevant international sanctions lists.

Step 3: Identify Confirmed Matches

• If a screened name matches the local or UNSC list:
  • For new or prospective customers:
    • Reject the customer and refrain from establishing any business relationship.
  • For existing customers:
    • Freeze all funds or assets immediately.
    • Terminate the business relationship within 24 hours.

Step 4: File the Fund Freeze Report

• Access the goAML platform to file the FFR.
• Ensure the report is filed within five calendar days of identifying the confirmed match.
• Include the following details in the FFR:
  • Information about the confirmed match.
  • Whether freezing measures have been applied to any funds or assets.

Step 5: Implement Freezing Measures

• For existing customers identified as confirmed matches:
  • Freeze their funds or assets under your possession immediately.
  • Ensure that no further services are provided to the sanctioned individual.

Conclusion

To maintain compliance with AML laws in the UAE, it is critical to conduct thorough customer screenings and take immediate action upon identifying confirmed matches with terrorist lists. Remember to file the Fund Freeze Report promptly on the goAML platform and apply freezing measures as required. By following these steps, you can help prevent financial crimes and ensure your business adheres to legal obligations.