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Record keeping, disclosure and compliance

Record-keeping and disclosure requirements

What record-keeping and disclosure requirements apply to companies and relevant individuals under the anti-money laundering, terrorism financing and fraud legislation?

Banks and other financial institutions in the United Arab Emirates are required to identify their customers, including beneficial ownership. There is an obligation to understand the ownership and control structure of all legal entities. There is also an ongoing obligation in respect of customer due diligence (CDD).

Enhanced CDD is required for:

  • politically exposed persons;
  • dealers in precious metals or stones;
  • real estate brokers;
  • dealers in luxury goods;
  • auction houses;
  • private banking clients; and
  • non-resident account holders.

Banks and other financial institutions in the United Arab Emirates are required to investigate all unusual transactions and to record their findings in writing. These records must be maintained for at least five years. Where the institution determines that the transaction is suspicious, it must make a report to the UAE Central Bank.

The obligation to report occurs at the point where there are reasonable grounds to suspect that the funds in question are proceeds of a criminal activity or to be used for terrorism, a terrorist act or for financing terrorism.

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