A relevant person must develop and implement anti-money laundering (AML) policies, procedures, systems, and controls to timeously address, investigate and dispose of alerts generated by the ongoing monitoring system, indicating potential money laundering (ML) or terrorism financing (TF) risk.

This Practice Note will provide an overview of how a relevant person can manage and dispose an alert-based suspicion triggered by the ongoing transaction monitoring system, to mitigate ML/TF risks effectively.

• AML: Anti-money laundering.

• Authorised person: Authorised firm or an authorised market institution.

• Authorised firm: An authorised person who holds a licence to carry on one or more financial services in or from the DIFC and is not an authorised market institution.

• Authorised market institution: An authorised person operating an exchange, a clearing house or an alternative trading system.

• Beneficial owner: A beneficial owner includes the following:

  • In relation to a customer, means a natural person who ultimately owns or controls the customer or a natural person on whose behalf a transaction is conducted, or a business relationship is established.

  • In relation to a body corporate:

    • The natural persons who ultimately have a controlling ownership interest in the body corporate, whether legal or beneficial, direct or indirect.