Initial AML setup for Real Estate Agents

AML COMPLIANCE REQUIREMENTS FOR NEWLY FORMED REAL ESTATE COMPANY IN THE UAE


Below are the AML compliance measures that should be performed as soon as you open the company.



1. goAML Registration 

As per the Federal Decree Law No. (20) of 2018 and the Cabinet Decision No. (10) of 2019, it is mandatory to have adequate processes and systems in place to enable designated entities to report suspicious transactions related to money laundering and terrorism financing.

 

Without registration on the goAML portal, designated entities cannot file any reports with the UAE FIU. With the goAML portal, the designated entities can help the regulatory authorities identify financial crimes and related suspicious activities.


If a designated entity does not register with the FIU goAML Portal, it would be subject to fines starting from AED 50,000.  Read more >>>



2. Appoint Compliance Officer

As per the UAE Anti-Money Laundering (AML) law, Real Estate Agents must appoint an AML Compliance Officer. The role of such an officer is to comply with the anti-money laundering laws as per - Federal Decree-law No. (20) of 2018.


The AML Compliance Officer must ensure that company have robust internal control procedure to detect transactions in financial crimes and to conduct training to relevant employees of the company. The Compliance Officer needs to update the relevant authorities and comply with the latest rules & regulations. The AML Compliance Officer has to submit the reports relevant report to the concerned authorities. 


Failure to appoint AML Compliance officer could result in fines more than AED 50,000. Read more >>>



3. AML/CFT Policy, Control and Procedures Documentations

A policy statement is a document that includes your AML/CFT policy, controls, and the procedures your business will take to prevent money laundering. This can also help with on-boarding new employees to make sure they know the process for identifying and verifying customers. This should detail:


  • Your AML/CFT policy and procedures – including naming relevant individuals and their responsibilities.
  • Your procedures on a risk-based approach for identifying and verifying customers.
  • Your commitment to training employees so they’re aware of their responsibilities and the need to promptly report suspicious activity to the nominated officer.
  • A summary of the monitoring controls that are in place.


Failure to prepare AML/CFT policy, control and procedures documents could result in fines more than AED 50,000. Read more >>>



3. AML/CFT Training Programme 

AML training programs are for employees to make them aware of the significance of AML/CFT rules & regulations. Organizations must conduct relevant AML training programme before starting the business.


Such AML-related training enables the employees to become capable of detecting suspicious transactions, conducting customer identification, identifying risks for their business type, and understanding implications of relevant rules and regulations.


Failure to provide relevant AML training to the staff could result in minimum fines of AED 50,000. Read more >>>


Once the company has complied with the above requirements, there are ongoing AML requirements for Real Estate Agents as below:


  • AML Business Risk Assessment
  • Annual AML/CFT Risk Assessment Report
  • Regulatory Reporting
  • KYC & Customer Due Diligence (CDD)
  • Record Keeping Requirements 
  • Independent Audit of AML System

What AML records shall I keep as an estate agent & Broker in the UAE?

What is goAML Registration?

What is AML Compliance Health Check?

 
 
 
 

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