The FATF research highlighted a trend in the use of complex commercial arrangements by money launders and terrorism financiers to hide their money trail. These arrangements often use the services of professionals such as lawyers, accountants and company secretaries. Arising from these typologies, the FATF standards require countries to improve their Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) measures on DNFBPs. The acronym of the day is “DNFBP”, or Designated Non-Financial Businesses and Professions. It is the FATF catch-all for any business or profession that poses a money laundering risk but cannot be classified as a financial institution. Thus, the risks related to this sector lie in the potential misuse for ML/TF.

What Are DNFBPs and Why Should You Care?

Financial establishments likewise have some regulations to combat Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) and these businesses must adhere to the regulations. The avoidance of money laundering activities not only applies to financial organizations functioning as banks but still issued some guidance on FATF Designated Non-Financial Businesses and Professions (DNFBP).

Obligations of Designated Non-Financial Business and Professions

As per the DNFBPs guidelines, DNFBPs in UAE must develop effective AML/CFT policies, practices, controls, and procedures to spot suspicious transactions and report them to prevent money laundering activities

What kind of Business falls into the DNFBP category
  • Auditors, external accountants, and tax advisors
  • Casinos and other gambling service providers
  • Company service providers
  • Dealers in precious metals
  • Dealers in precious stones
  • Lawyers
  • Notaries and other independent legal professionals
  • Real estate agents
  • Trusts
  • Real Time Business Solution

    Circuit Computer provide real time business solutions which may help to streamline the DNFBPs business processes. Circuit Computer focus on the needs of customers and designed the LiveEx DNFBPs solutions as per the FATF recommendations.
    The LiveEx-Shield system provides comprehensive dashboard after the successful login for quick analysis. Live EX provides real time business solutions which may help to streamline the DNFBPs business processes. Circuit Computer focuses on the needs of customers and designed the LiveEx DNFBPs solutions as per the FATF recommendations, Central bank Of the UAE, Ministry of Economy, FIU and other international standards.

    Chapter 16 of the Standards for the Regulations Regarding Licensing and Monitoring of Exchange Business, Version 1.20 of November 2021 amending Version 1.10 of February 2018 (Central Bank Of the UAE)

    Download the Anti-Money Laundering Guidelines for Designated Non-Financial Entities and Industries (DNFBPs) issued by the United Arab Emirates Ministry of Economy (MOE).

    Regulatory - Standards

    16.14.1 EDD is required before entering into any business relationship with, or processing any transactions for, DNFBPs as defined under the AML-CFT Decision. DNFBPs may be natural or legal persons. 16.14.2 The Licensed Person must implement appropriate, procedures, systems and tools to determine whether a customer is a DNFBP. 16.14.3 Where a customer is determined to be a DNFBP, the Licensed Person must carry out the following required steps, in addition to the CDD and EDD required by Paragraph 16.11 of these Standards and any other EDD appropriate to manage the risk of the customer:
    a) Verifying that the customer has the required licenses; b) Obtaining information sufficient to determine that the customer is compliant with the AML/CFT preventive measures required under AML-CFT Decision; c) Take additional steps to understand the customer’s business, including the products and services it offers, its geographic footprint, and its customer base; d) Obtain approval from the Compliance Officer and the Manager in Charge of the Licensed Person before establishing the business relationship or processing any transactions.

    Tipping-off and confidentiality Financial institutions, their directors, officers and employees should be: (a) protected by law from criminal and civil liability for breach of any restriction on disclosure of information imposed by contract or by any legislative, regulatory or administrative provision, if they report their suspicions in good faith to the FIU, even if they did not know precisely what the underlying criminal activity was, and regardless of whether illegal activity actually occurred; and (b) prohibited by law from disclosing (“tipping-off”) the fact that a suspicious transaction report (STR) or related information is being filed with the FIU. These provisions are not intended to inhibit information sharing under Recommendation 18. The requirements set out in Recommendations 18 to 21 apply to all designated non-financial businesses and professions, subject to the following qualifications:
    a) Lawyers, notaries, other independent legal professionals and accountants should be required to report suspicious transactions when, on behalf of or for a client, they engage in a financial transaction in relation to the activities described in paragraph (d) of Recommendation 22. Countries are strongly encouraged to extend the reporting requirement to the rest of the professional activities of accountants, including auditing. b) Dealers in precious metals and dealers in precious stones should be required to report suspicious transactions when they engage in any cash transaction with a customer equal to or above the applicable designated threshold. c) Trust and company service providers should be required to report suspicious transactions for a client when, on behalf of or for a client, they engage in a transaction in relation to the activities referred to in paragraph (e) of Recommendation 22.

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      Customer Onboarding
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      Risk Base Approach
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      Case Management

    The LiveEx DNFBPs system provides :

    • Real-Time Sanction Screening
    • KYC , CDD/SDD/EDD Templates
    • RBA - Framework
    • Risk Mitigation Modules
    • Legal/Natural Link Analysis
    • GoAML Integration
    • Documents Repository
    • MIS & EI
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